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October 14, 2008 

BIS to Require Electronic Submission of License Applications and Other Submissions Starting October 20, 2008

The era of filing paper license and commodity classification requests with the Commerce Department's Bureau of Industry and Security (BIS) is soon coming to an end.

As a result of the final rule issued by BIS in August, starting next Monday, October 20, 2008, the following types of submissions must be submitted via the web-based Simplified Network Application Process Redesign (SNAP-R) system:

  • Export license applications (other than Special Comprehensive License and Special Iraq Reconstruction License applications);
  • Reexport license application;
  • Commodity classification requests;
  • Encryption review requests;
  • License Exception AGR notifications;
  • All documents submitted in support of or related to the above submissions.
The final rule states that BIS will authorize paper submissions in only a few limited situations, such as when:
  1. BIS has received no more than one submission from the party in the twelve months immediately preceding the current submission, i.e., the combined total of the party's license applications (other than Special Comprehensive Licenses), encryption review requests, License Exception AGR notifications, and classification requests could not exceed one;
  2. The submitter does not have access to the Internet;
  3. BIS has rejected the party's electronic filing registration or revoked its eligibility to file electronically;
  4. BIS has requested that the party submit on paper for a particular transaction; or
  5. BIS has determined that urgency, a need to implement government policy or a circumstance outside the submitting party's control justifies allowing paper submissions on a particular instance.

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