Service · US content & de minimis
Is your non-US product subject to US export rules? For which destinations, and why.
For manufacturers and integrators outside the US whose products contain US-origin components, software or technology. Especially useful when a customer, bank or distributor asks whether your product is "EAR-free", when you bid for a sensitive contract, change suppliers, or face a due-diligence review.
In two lines
We confirm the origin and ECCN of each relevant component, calculate the US content per destination against the 25%, 10% or zero threshold, check the foreign direct product and ITAR rules, and give you a signed analysis plus a one-page summary for customers and banks.
What the service covers
- Bill of materials review. Origin and US classification (ECCN) of each relevant component, including embedded software and technology, rather than relying on supplier declarations alone.
- De minimis calculation by destination. The US content that counts for each destination, the percentage, and the applicable threshold: 25%, 10%, or no de minimis at all for certain items.
- Foreign direct product rule check. Whether your product could be caught even with little or no US content, because it is made with certain US technology, software or production equipment.
- ITAR check. That no ITAR-controlled component brings the whole product under ITAR.
- BIS one-time report. Where you rely on de minimis for software or technology, we prepare the required report.
- Design options. Where the result is close to a threshold, we show which components drive it and what replacing them would change.
What you provide
- The bill of materials, with part numbers, suppliers, quantities and unit costs.
- Supplier classification and origin statements, where you have them.
- The product's selling price or fair market value.
- The destinations and end users you want covered.
We send a simple template at the start and follow up with your engineering and purchasing teams on any gaps.
What you receive
- A written analysis for each product: components reviewed, origins, classifications, values, calculation per destination, rule checks and conclusion. Signed off and ready for your compliance file or an audit.
- A one-page summary you can share with customers, banks and partners: subject to the EAR or not, for which destinations, and on what basis.
- A component register of US-origin parts with their classifications, reusable for future products.
How it works
Scoping callFree, 30 minutes: products, destinations, data.
Fixed-fee proposalBased on the number of products and the size of the bill of materials.
AnalysisTypically 5 to 10 working days per product once the data is complete.
Review meetingResults and design options walked through.
Pricing options: single product; product family (reduced fee for variants sharing most components); annual review when the bill of materials, suppliers, prices or US rules change.
Start with the item you are not sure about.
A free 30-minute scoping call, or the 15-question assessment.