U.S. Exporters Reminded that License Code C32 Will No Longer Be Accepted in the Automated Export System on April 1st

By Melissa Miller Proctor

Just a reminder to U.S. exporters that on April 1, 2017, License Code C32 will no longer be accepted into the Automated Export System (AES) as part of the Electronic Export Information (EEI) filing process, and filers reporting License Code C32 will begin receiving fatal errors on that date. In order to avoid any compliance hiccups during the U.S. export clearance process, U.S. exporters should ensure that they have made the required updates to their internal systems for self-filings of the EEI, or have confirmed that their authorized AES filers have made changes to their respective systems.

By way of background, License Code C32 was previously used for No License Required (NLR) export shipments consisting of items controlled on the Commerce Control List for reasons other than (or in addition to) Anti-Terrorism reasons. However, as of October 1, 2016, the Commerce Department’s Bureau of Industry and Security (BIS) removed AES License Code C32. AES filers were given 180 days (6 months) to comply with this change. As noted above, on April 1st, License Code C32 will no longer be accepted. Rather, License Code C33 should be used for all NLR shipments with the exception of NLR shipments containing items classified in 600-series Export Control Classification Numbers (ECCNs) or in ECCN 9×515 having a .y paragraph, which should be reported as License Code C60(DY6).

The removal of License Code C32 was made as a result of several requests received from the export community asking for simplification of NLR reporting in the AES. A complete list of all of the AES License Type codes and reporting instructions can be found in Appendix F of U.S. Customs and Border Protections’ Automated Export System Trade Interface Requirements publication, which is available online here.

If you have questions about export license and license exemption type codes, U.S. export requirements, or other international trade issues, please feel free to contact a member of Polsinelli’s International team, including Melissa Proctor at mproctor@polsinelli.com.