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Reminder for the U.S. Export Administration Regulations’ (EAR) Encryption Reporting Deadline

Under the U.S. Export Administration Regulations (EAR), 2017 brings exporters reporting deadlines for the export of encryption items. These periods also provide an excellent opportunity for a business to perform an export compliance check-up to review changes to the encryption functionality of current products or assess new product offerings.

For encryption, items exported or re-exported during calendar-year 2016 (January 1 through December 31, 2016), and semi-annual reports for specified encryption items exported or re-exported between July 1 and December 31, 2016, the deadline for submitting annual self-classification reports is February 1, 2017.

Please note, as of September 20, 2016, recent amendments to the EAR’s encryption controls removed the requirements for organizations to submit annual self-classification reports if they already have a formal commodity classification or Commodity Classification Automated Tracking System (CCATS) for encryption products.

To get rid of your annual self-classification reporting worries in the future, please contact OCEANAIR Compliance to learn more about how to obtain a CCATS from the Department of Commerce. Additionally, if you need help with determining whether the encryption export controls and reporting deadlines apply to your business, please contact our Compliance team at (781) 286-2700 or compliance@oceanair.net.