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Is there guidance on the type of documentation that is needed for relying on the “development” ‘releases’ under paragraphs (b)(4), (b)(5) and (b)(6)?



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Yes. The Note to paragraphs (b)(4), (b)(5) and (b)(6) identifies the type of documentation required in order to rely on the “development” ‘releases.’ The Note to paragraphs (b)(4), (b)(5) and (b)(6) includes an illustrative list of such documents.

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Next Looking at the definition of “part,” it is clear to me that if I make a cast of a commodity and that commodity is a single unassembled element of a “component,” “accessory,” or “attachment,” which is not normally subject to disassembly without the destruction or the impairment of design use, that it would be clearly identifiable as a “part.” However, there are other manufacturing processes that can be used to create the same commodity, i.e. welding or diffusion bonding, which technically would be combining two different elements, but substantively would be creating the same type of commodity (i.e., both would be single unassembled elements of a “component,” “accessory,” or “attachment” which are not normally subject to disassembly without the destruction or the impairment of design use). Does the manufacturing method make a difference in whether a commodity is considered a “part”?
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