The Bureau of Industry and Security has issued a reminder that shipments to Cuba of items subject to the Export Administration Regulations require the use of the Automated Export System code corresponding to the appropriate BIS license exception and should not be coded as NLR (no license required).
BIS states that all items subject to the EAR require authorization for export to Cuba by either an individual validated license or a license exception. If an item is eligible for shipment under a license exception it is incumbent upon the exporter to properly report in AES. However, in recent months BIS has identified many transactions coded as NLR (code C32/C33) that were not properly filed under the correct AES code corresponding to the appropriate BIS license exception.
According to BIS, only shipments of informational materials and certain other items that are not subject to the EAR may be designated in AES as NLR. All other shipments of items require use of the appropriate AES code corresponding to the BIS license exception. For example, eligible shipments to Naval Station Guantanamo Bay should be made under license exception GOV (code C42) and eligible shipments of gift parcels to family members in Cuba should be made under license exception GFT (code C43). In addition, items eligible for license exception Support for the Cuban People should be made under license exception SCP (Code C62).
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