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I want to export impellers made of materials which meet the control parameters for agitators controlled under ECCN 2B350. Do I need a license since the impeller alone doesn't constitute an agitator?
Individual components of equipment controlled under 2B350 are not controlled under 2B350 and do not require an export license to most destinations. However, Section 764.2(h) of the EAR prohibits exporters from engaging in transactions (such as disassembling equipment and exporting it as separate parts) with the intent to evade export controls. Also, impellers that are subject to the EAR are subject to the end-use restrictions described in Part 744.
Bureau of Industry & Security (BIS),USDOC
http://www.bis.doc.gov/
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