Export Control Guidance

Export Control Guidance for Owen Oil Tools International Sales

 Know your customer

OOT export sales staff must know their customer and how they intend to use OOT products. Excellent guidance on this topic is available from the Bureau of Industry and Security (formerly the Bureau of Export Administration) by clicking here.

Be sure to:

1. Check for “Red Flags”. For more information on “red flags” click here.

2. Check the “Denied Parties List”. If a customer is on this list, do not accept their order. The “Denied Parties List” is available by clicking here or as an XLS file by clicking here.

3. Check the “Entities List”. If a customer is on this list, do not accept their order. The “Entities List” is available by clicking here.

4. Examine all customer documents, letters, requests for quotes, contracts, etc. for boycott language, and if any is found, contact John Denson of CoreLab.

 Determine whether the product requires an export license

1. Determine the product’s ECCN

a. Go to HAZLIST On-Line by clicking here.

b. Click “Enter a Query”.

c. Enter part number in “Part # must match” box and click the submit button. Wild card characters may be used (* for any characters, ? for specific characters).

d. ECCN is found in the Product Section (see figure 1).

ECCN location

2. Make a licensing determination

a. Go to the Export Controls page of the OCS website by clicking here.

b. Click the link to “Commodity Classification”. c. Locate the ECCN of the product in the table and click the ECCN number. This will take you to the Export Control Summary for the product to be exported. Review the following sections of the ECCN entry:

i. License exceptions – this section describes the conditions (if any) under which a license exception may be used.

ii. NLR (no license required) – this section describes the conditions (if any) under which the product may be exported NLR.

iii. No exports allowed – this sections lists the countries to which no exports of the product are allowed.

iv. IVL required – this section lists the countries to which an IVL (individual validated license) is required, unless a license exception or NLR is available.

 Process the order in accordance with licensing requirements

1. License required. If an export license is required, provide the following information to OCS:

a. Name, address (physical, no P.O. Box), phone number, fax number, email address and contact name of purchaser.

b. Name, address (physical, no P.O. Box), phone number, fax number, email address and contact name of ultimate consignee.

c. Name, address (physical, no P.O. Box), phone number, fax number, email address and contact name of end-user.

d. A copy of the customer order.

OCS will review the documentation and submit a license application if appropriate. You should advise your customer that an export license may be required and that delivery of the order is contingent upon issuance of the required license. Also, you should advise your customer that they may be contacted by OCS regarding completion of an end-user statement and that the statement should be completed and returned without delay. The license application cannot be submitted for approval until the statement (if required) is completed and returned to OCS.

2. No license is required. If no license is required, then the order may be processed following published OOT procedures.

 Contact information

David Boston John Denson Owen Compliance Services, Inc. Core Laboratories, LP P.O. Box 40150 6316 Windfern Fort Worth, TX 76140 Houston, TX 77040 Tel: (817) 551-0660 Tel: (713) 328-2104 Fax: (817) 551-1032 Fax: (713) 744-6225 email: [email protected] email: [email protected] web: www.ocsresponds.com web: www.corelab.com