Export Control Reminder: Encryption Reporting Deadline 2/1/17
The new year brings with it the reporting deadlines for exports of encryption items under the US Export Administration Regulations (“EAR”). February 1, 2017 is the deadline for submitting annual self-classification reports for encryption items exported or re-exported during calendar year 2016 (January 1 through December 31, 2016), as well as semi-annual reports for specified encryption items exported or re-exported between July 1 and December 31, 2016.
Note that due to recent amendments to the EAR’s encryption controls, effective September 20, 2016, companies that have obtained a formal commodity classification or CCATS for certain encryption products are no longer required to submit annual self-classification reports. Please contact us to learn more about how to obtain a CCATS from the Commerce Department and eliminate your annual self-classification reporting burden going forward.
The new year is also a good time to conduct an export compliance check-up, including an assessment of any new product offerings or changes to the encryption functionality of existing products.
If you would like assistance determining whether the encryption export controls and reporting deadlines apply to your products and associated technology, please contact a member of our team.
This content is provided for general informational purposes only, and your access or use of the content does not create an attorney-client relationship between you or your organization and Cooley LLP, Cooley (UK) LLP, or any other affiliated practice or entity (collectively referred to as “Cooley”). By accessing this content, you agree that the information provided does not constitute legal or other professional advice. This content is not a substitute for obtaining legal advice from a qualified attorney licensed in your jurisdiction and you should not act or refrain from acting based on this content. This content may be changed without notice. It is not guaranteed to be complete, correct or up to date, and it may not reflect the most current legal developments. Prior results do not guarantee a similar outcome. Do not send any confidential information to Cooley, as we do not have any duty to keep any information you provide to us confidential. This content may be considered Attorney Advertising and is subject to our legal notices.