Archive: Aug 2020

Selling our Products Overseas: An Export Control Overview

Leave a Comment

Paulson Mfg. has a rich history of making and selling world-class PPE right here in the U.S. However, our reach goes well beyond the U.S. market. In fact, we export to about 70 different countries across the globe through our wholly owned subsidiary Paulson International, Ltd. Based in Frankfurt, Germany, Paulson International serves our ever-growing global markets.

While exporting products overseas should be a fundamental aspect of a manufacturer’s business model, it is critical to know how to navigate this often-complex business landscape. This is especially true for products deemed sensitive in nature by the U.S. government, which controls exports of sensitive equipment, software, and technology to promote our national security interests and foreign policy objectives. For example, exporting one of our welding face shields can be accomplished with relative ease. This is not the case with exporting one of our tactical face shields designed for ballistic combat helmets worn by law enforcement and military personnel. Due to the sensitive nature of this product as it relates to U.S. national security, an exporter must go through the proper channels to ensure it follows the rules laid out by the U.S. government.

export control

Through their export control system, the U.S. government can effectively:

  • Provide for national security by limiting access to the most sensitive U.S. technology and weapons
  • Promote regional stability
  • Take into account human rights considerations
  • Prevent proliferation of weapons and technologies, including of weapons of mass destruction, to problem end-users and supporters of international terrorism
  • Comply with international commitments, i.e. nonproliferation regimes and UN Security Council sanctions and UNSC resolution 1540

Department of Commerce and Bureau of Industry & Security (BIS)

Under the current export control system, three different government agencies have the authority to issue export licenses—the Departments of State, Commerce, and the Treasury. At Paulson Mfg., our exporting activities are subject to the Export Administration Regulations (EAR) set forth by the Bureau of Industry & Security (BIS). This agency of the Department of Commerce is led by the Under Secretary of Commerce for Industry and Security.

The BIS seeks to advance U.S. national security, foreign policy, and economic interests, with activities including the regulation of the export of sensitive goods and dual-use technologies. They enforce export control, anti-boycott, and public safety laws; cooperate with and assist other countries on export control and strategic trade issues; assist U.S. industry to comply with international arms control agreements; monitor the viability of the U.S. defense-industrial base; and promote federal initiatives and public-private partnerships to protect the nation’s critical infrastructures.

Items on the Commerce Control List (CCL), including many sensitive goods and technologies, require an export license from the Department of Commerce before they can be exported. To determine whether an export license is required, an Export Control Classification Number (ECCN) is used. Again, if an electrical contractor in Brazil needs an arc flash face shield, or a steelworker in the U.K. needs a gold coated face shield, we can get these products to them fairly easily (i.e., without the need of an export license). However, if an overseas government agency has a need for our tactical products, such as our riot control PPE, more often than not, an export license would need to be furnished prior to being able to export those types of goods.

Paulson Mfg. manufactures five primary product lines—Arc Flash PPE, Industrial PPE, Law Enforcement & Military PPE, Firefighter PPE, and Medical PPE. Of those lines, only our Law Enforcement & Military PPE products (classified by the Department of Commerce as “Crime Control” products) would be subject to EAR and would therefore most likely require an export license to sell overseas. To see the complete list of countries and export controls for various product types, click here. There are certain countries that are embargoed that we cannot ship any products to. An example of this would be North Korea. This is crucial to know if you are selling products overseas for a business.

Applying for an Export License

Once you have determined that the item you want to export needs a license under jurisdiction of the Department of Commerce, you can go to the BIS website and begin the process of registration. This is done through SNAP-R (Simplified Network Application Process – Redesign), which  allows users to submit export license applications. You must register for SNAP-R by first getting a Company Identification Number (CIN) and activating a user account. Follow the procedures listed on the website to get started. If you have questions or need help, you can call the SNAP-R Help Desk at (202) 482-2227. Once you are registered, you can access SNAP-R and apply for your license. Paulson Mfg. can assist you in this process and also apply for the needed license, as long as it is for our products. This is just another benefit of selling products overseas for a business and working with Paulson Mfg.

World-Class PPE for a Global Marketplace

Since 1947, Paulson Mfg. has been making the highest quality PPE for industrial workers and first responders. Our products are made in the U.S. and distributed to frontline workers and officers across the globe. As we look to the future, we believe our business overseas will continue to grow and grow (95% of our potential customers live outside of the U.S.). While this is great news for the future of our company, it is critical that everything we export is processed through the proper channels based on what type of product it is. We are aligned with the Department Commerce & BIS in their stated mission of enhancing U.S. exports while mitigating any threats to our national security.

shipping products overseas

To learn more about selling our products overseas and why it should be a fundamental aspect of a manufacturer’s business model, please contact us today.