Export Control Guidance for Owen Oil Tools International Sales
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Know your customer (updated 10/11/2004)
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Process the order in accordance with licensing requirements (updated 12/22/2005)
OOT export sales staff must know their customer and how they intend to use OOT products. Excellent guidance on this topic is available from the Bureau of Industry and Security (formerly the Bureau of Export Administration) by clicking here.
Be sure to:
1. Check for "Red Flags". For more information on "red flags" click here.
2. Check the "Denied Parties List". If a customer is on this list, do not accept their order. The "Denied Parties List" is available by clicking here or as an XLS file by clicking here (updated 10/11/2004),
3. Check the "Entities List". If a customer is on this list, do not accept their order. The "Entities List" is available by clicking here (updated 10/11/2004).
4. See also, BIS's Lists to Check page at the BIS website by clicking here (added 10/11/2004).
5. Examine all customer documents, letters, requests for quotes, contracts, etc. for boycott language, and if any is found, contact Mark Elvig of CoreLab.
¨ Determine whether the product requires an export license
1. Determine the product’s ECCN
a. Go to HAZLIST On-Line by clicking here.
b. Click "Enter a Query".
c. Enter part number in "Part # must match" box and click the submit button. Wild card characters may be used (* for any characters, ? for specific characters).
d. ECCN is found in the Product Section (see figure 1).
2. Make a licensing determination
a. Go to the Export Controls page of the OCS website by clicking here.
b. Click the link to “Commodity Classification”.
c. Locate the ECCN of the product in the table and click the ECCN number. This will take you to the Export Control Summary for the product to be exported. Review the following sections of the ECCN entry:
i. License exceptions – this section describes the conditions (if any) under which a license exception may be used.
ii. NLR (no license required) – this section describes the conditions (if any) under which the product may be exported NLR.
iii. No exports allowed – this sections lists the countries to which no exports of the product are allowed.
iv. IVL required – this section lists the countries to which an IVL (individual validated license) is required, unless a license exception or NLR is available.
¨ Process the order in accordance with licensing requirements/Request an Export License (updated 12/22/2005)
1. License required. If an export license is required, complete and submit:
a. An Export License Request form to OCS per the instructions on the form (click here for additional information) and
b. A copy of the customer order or sales quote (must show part numbers, quantities, and prices)
OCS will review the documentation and submit a license application if appropriate. You should advise your customer that an export license may be required and that delivery of the order is contingent upon issuance of the required license. Also, you should advise your customer that they may be contacted by OCS regarding completion of an end-user statement and that the statement should be completed and returned without delay. The license application cannot be submitted for approval until the statement (if required) is completed and returned to OCS.
2. No license is required. If no license is required, then the order may be processed following published OOT procedures.
David Boston
Owen Compliance Services, Inc.
P.O. Box 765
Godley, TX 76044-0765
Tel: (817) 551-0660
Fax: (817) 396-4584
email: david.boston@corelab.com
web: www.ocsresponds.com
Mark Elvig (general
guidance questions only ... do not contact for specifics about requesting an
export license)
Core Laboratories, LP
6316 Windfern
Houston, TX 77040
Tel: (713) 328-2104
Fax: (713) 744-6225
email: mark.elvig@corelab.com
web: www.corelab.com