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License Exceptions & Exemptions:

“No License Required”

Both the Departments of Commerce (BIS-EAR) and State (DDTC-ITAR) regulations contain license exemptions/exceptions that exporters can utilize to make exports without the need for an export license. In addition, the Bureau of Alcohol Tobacco, Firearms and Explosives regulation (ATF- Importation of Arms, Ammunition and Implements of War) also contains exemptions to the requirement for an import permit for the importation of Defense Articles.

• Department of Commerce (BIS) – License Exceptions
- Authorization by the Department of Commerce that allows a person to export or re-export under stated conditions, items subject to the Export Administration Regulations (EAR) that would otherwise require a license
• Department of State (DDTC) – License Exemptions
- Authorization by the Department of State for a person to approve, for their company, the export, re-export, or temporary import of items contained on the US Munitions List without a license/agreement
• Bureau of Alcohol Tobacco and Firearms and Explosives (ATF) – Permit Exemptions
Authorization by the Bureau of Alcohol Tobacco, Firearms and Explosives for a person to approve, for their company, the permanent import of items contained on the US Munitions Import List without a permit

By using any license exemptions/exceptions the exporter/importer is certifying that the terms, provisions, and conditions for the use of the exemption/exception as described in the regulations have been met

There are numerous exceptions and exemptions available to exporters and importers, but determining which one to use and whether it fits a particular transaction can often be a confusing and difficult exercise. In addition, there can be numerous administrative, shipping, certification and/or reporting requirements associated with their use.


ITC Strategies is well versed in all the US Government exemptions and exceptions available for use by exporters and importers. We can assist companies in determining their applicability for a particular transaction, how to utilize them correctly when making a shipment or export, and what is needed in terms of the associated follow-on requirements.