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I manufacture luxury pens with a Teflon writing tip. I understand that Teflon can contain substantial amounts of PFIB, a CWC controlled Schedule 2A chemical. Do I have to get a license now to export my pens?
No. PFIB is a CWC Schedule 2A chemical controlled under Export Control Classification Number 1C355 of the Export Administration Regulations (EAR). Consumer products for retail sale containing Schedule 2 chemicals may be exported without a license. Regarding the export of a Teflon product that would not meet the definition of a consumer product: Under the EAR, export of PFIB requires a license if it is present in a mixture that contains more than 1% free PFIB. A mixture is made up of two or more components which do not react together under the conditions under which the mixture is stored; they can be separated by physical means. PFIB in Teflon is irreversibly reacted into Teflon and no longer can be separated readily. Therefore, the export of Teflon in its standard form is not considered to be the export of a mixture containing PFIB.
Bureau of Industry & Security (BIS),USDOC
http://www.bis.doc.gov/
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