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If I determine my commodity is not classified under an ECCN, such as an ECCN in a “xY0zz” ECCN that does not control “parts,” does that mean that all the “technology” related to my “part” is not controlled either?



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In many cases the classification of a commodity’s “technology” will be related to the classification of the commodity, but there are several exceptions. For example, “technology” may be more highly controlled than the related commodity. But generally speaking if the “part” was not controlled under a specific ECCN then the related “technology” would not likely be controlled either. However, an important qualifier is that if the “technology” is related to other elements of that same commodity, then a separate “technology” analysis must be conducted with respect to the other “component,” “accessory,” or “attachment.”

Previous If I complete the analysis of “specially designed” for my “component” that is subject to the EAR and determine the “component” is “specially designed,” is there any process under the EAR whereby I can request a U.S. Government review to determine whether the “component” does not warrant being “specially designed?”
Next If I develop a “part,” or “component” for use in different types of commodities, such as machine tools, medical equipment and aircraft, is there a paragraph (b) ‘release’ for such general purpose commodities or software?
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