I manufacture small industrial equipment in the United States that does not require a license for export to most destinations. Am I responsible for the end-use after the export?
Yes. There are several provisions in the Export Administration Regulations that make the exporter responsible for the end-use of the exported items. These provisions are primarily in the end-use restrictions set out in Part 744. (These restrictions are often informally referred to as “EPCI” rules. (Enhanced Proliferation Control Initiative.)) One example of a Part 744 restriction is the requirement to obtain an export license for an item that would otherwise not need one, if the exporter knows or is informed that the item will be used in the design, development, production, stockpiling or use of chemical or biological weapons in a country of concern. There are several other provisions of Part 744 that you should consult.
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