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Questions and Answers
What does License Exception RPL allow for?
What is the restriction for replacement parts, components, accessories, and attachments?
Who can export replacement parts, components, accessories, and attachments?
What must be done with replacement parts, components, accessories, and attachments after they are used?
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What is excluded from License Exception RPL?
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Which items are authorized under the Arms Export Control Act?
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What is the time limit for License Exception RPL for firearms?
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What is required for temporary importers of firearms under License Exception RPL?
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Who can make reexports of replacement parts, components, accessories, or attachments?
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What items are subject to special recordkeeping requirements under License Exception RPL?
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What records must be maintained by exporters for items exported under License Exception RPL?
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What must be included in annual or semi-annual reports of exports and reexports of '600 Series' items under License Exception RPL?
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What is the purpose of License Exception RPL?
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What items does License Exception RPL apply to?
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What is the restriction on replacement parts under License Exception RPL?
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Who can export replacement parts under License Exception RPL?
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What must be done with replacement parts after they are used for repair?
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What is excluded from License Exception RPL?
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What is the maximum time period for temporary export of firearms under License Exception RPL?
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What is the requirement for firearms to qualify for temporary export under License Exception RPL?
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Who must provide a statement to U.S. Customs and Border Protection for temporary import of firearms under License Exception RPL?
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What is required for exporters or their agents for temporary export of firearms under License Exception RPL?
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What are the recordkeeping requirements for items exported or reexported pursuant to License Exception RPL to repair, replace, or service previously lawfully exported items?
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Who may request the records of items exported or reexported pursuant to License Exception RPL?
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Study Notes
License Exception RPL for Servicing and Replacement of Parts and Equipment
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License Exception RPL allows for exports and reexports of one-for-one replacement parts, components, accessories, and attachments.
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License Exception RPL also applies to certain items currently "subject to the EAR" and authorized under the Arms Export Control Act.
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License Exception RPL does not apply to defense articles subject to ITAR.
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Replacement parts, components, accessories, and attachments must be for the immediate repair of equipment or other end items and cannot improve or change basic design characteristics.
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Replacement parts, components, accessories, and attachments may only be exported to replace those contained in commodities that were lawfully exported, reexported, or made in a foreign country incorporating authorized parts.
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Replacement parts, components, accessories, and attachments may only be exported by the party who originally exported or reexported the commodity to be repaired or by a party that has confirmed the existence of appropriate authority for the original transaction.
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Replacement parts, components, accessories, and attachments must either be destroyed abroad or returned promptly to the person who supplied the replacements or to a foreign firm under their effective control.
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License Exception RPL excludes replacement parts, components, accessories, or attachments exported under a condition that any subsequent replacements may be exported only under a license.
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Replacement parts, components, accessories, or attachments cannot be exported to be held abroad as spares for future use.
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Replacement parts, components, accessories, or attachments cannot be exported to countries listed in supplement no. 3 to part 744 of the EAR for certain nuclear end-use restrictions or to countries in Country Group E:1 designated as supporting acts of international terrorism.
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Reexports of replacement parts, components, accessories, or attachments must meet the same conditions as exports and can only be made by the party who originally exported or reexported the commodity to be repaired or by a party that has confirmed the existence of appropriate authority for the original transaction.
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License Exception RPL also authorizes the export and reexport of commodities and software sent for servicing and replacement of commodities and software "subject to the EAR" that are defective or unacceptable.Requirements and Recordkeeping for Exporting Firearms and Repairing Commodity Items under License Exception RPL
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License Exception RPL allows for the temporary export of firearms and the repair or replacement of previously lawfully exported items.
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The exception applies for up to one year or the time it takes to service or replace the commodity, whichever is shorter.
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To qualify, the firearms must not have been shipped from or manufactured in certain countries, unless specified under Annex A in Supplement No. 4 to this part.
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Temporary importers or their agents must provide a statement to U.S. Customs and Border Protection, along with appropriate import-related documentation, including a complete list and description of the firearms being temporarily imported.
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If temporarily imported for servicing or replacement, the importer must provide the name, address, and contact information of the organization or individual in the U.S. that will be receiving the item.
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Exporters or their agents must provide import documentation related to the temporary export at the time of export, in addition to complying with all applicable EAR requirements.
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Additional procedures for temporarily importing or exporting firearms are available from U.S. Customs and Border Protection.
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Special recordkeeping requirements apply for items exported or reexported pursuant to License Exception RPL to repair, replace, or service previously lawfully exported items classified under ECCNs 2A983, 2A984, 2D983, and 2D984, or a "600 Series" ECCN.
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Exporters must maintain records of the description of the item replaced, repaired, or serviced, the type of repair or service, certification of the destruction or return of the item replaced, the location of the item, the name and address of the recipient, the quantity of items shipped, and the country of ultimate destination.
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These records may be requested at any time by a BIS official.
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Annual or semi-annual reports of exports and reexports of "600 Series" items under License Exception RPL must include certain records, as described in §§ 743.4 and 762.2(b) of the EAR.
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Compliance with these requirements and recordkeeping is necessary for exporters and temporary importers utilizing License Exception RPL.
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Description
Test your knowledge of License Exception RPL for the servicing and replacement of parts and equipment with this quiz. Learn about the conditions and requirements for the export and reexport of one-for-one replacement parts, components, accessories, and attachments, as well as the authorization for the export and reexport of commodities and software for servicing and replacement. Discover the limitations and restrictions on the use of License Exception RPL, including the exclusion of defense articles subject to ITAR and the prohibition of exporting to certain countries.
