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Impact of ECCN change on existing licenses

May 04 at 06:58 PM

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Former Member

When ECCNs need to be changed, what is the impact to existing export licenses related to the old ECCN? Will current licenses with former ECCN need to be expired and new licenses reflecting the new ECCNs need to be created?

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3 Answers

Mouaz BEN REDJEB May 07 at 10:00 AM
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Hi Wendy,

Well, the answer depends on multiple factors:

- If you expire your old license, you need to bear in mind that you can have logistics processes started but not finished: e.g. Sales Order covered by license, license is expired, when creating the outbound delivery it can be blocked because lacking the license to cover it

- If you expire your old license, do you want to run a new Compliance check against the new license for all logistics processes?

- Etc...

Maybe it can help by letting us know why you want to change the ECCN: Is it because the license was created (by user) with the wrong ECCN? Is it because local authorities have ended the license with the old ECCN and are issuing new licenses only valid for a new ECCN? Is it because business have applied for a new license with a new ECCN and are no longer allowed to use the old license with the old ECCN?

Regards.

Mouaz BEN REDJEB

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Former Member May 08 at 12:10 PM
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In this case, it was a change made by the government authorities.

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Nishant Grover May 09 at 03:40 AM
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Wendy, my comments:

  • When you change the ECCN codes (I am assuming you are creating new codes and / or reclassifying products), there is no automatic change done to license
  • It is possible to change the existing licenses to remove ECCN codes and add the new ones. That's normally not the best practice that I would recommend
  • My suggestion would be to create new license say v2 (if many details are same, copy license feature can be used) and update the older license (v1) validity period to a day before the new license is effective
  • As Mouaz has mentioned, the impacts of this change should be analyzed. Suggestion would be to use "Display Assigned Documents" to find all open document still assigned to v1 licenses.
  • All the impacted documents should be rechecked after the v2 licenses are created and v1 license validity is adjusted. If the document is covered under the new license, it will remain released (license assignment will change), else, it will be blocked.

Hope that helps.

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Totally aligned with Nishant's answer here.

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