Export Controls on Fluid Handling Equipment
Pumps & Systems
The article discusses the intensified focus on pump, valve and other fluid handling equipment companies by export control agencies. Specific enforcement emphasis has been placed on the broad, expanding export controls in the U.S. Export Administration Regulations, which covers pumps, valves, pipes, storage tanks, heat exchangers and other equipment that can be used for chemical processing. Export licenses are required from the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for multiple seal and seal-less pumps and essentially all valves, as well as certain pump and valve parts. The article outlines the specific product categories and situations companies should explore when exporting these materials. These categories include “Non-Core”, Vibration, Marine and Nuclear End Uses, Pressure Transducers/Skid Packages, Pressure Transducers/Skid Packages, Vacuum Pumps, and Encryption. It suggests that companies conducting or renewing export classifications of these non-core products should also carefully consider the separate software and technology controls, which are not well understood in the industry.