Carbon fiber export regulations

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#1

Hi,

I am planning on selling carbon fiber wallets and phone cases, but am worried about whether or not it might be legal. I will be using aerospace grade high strength carbon fiber in my products.

I remember reading that because of the dual use nature of carbon fiber (terrorists and “rouge states” such as Iran, China, and North Korea are desperate to use the stuff for nuclear weapons development), international law prohibits the export of carbon fiber for any uses other than sporting goods, automotive goods, and some other stuff. So I’m guessing it would be illegal to sell carbon fiber phone cases outside of the US?

What about selling inside the US?

Or does the law only apply to raw materials and not finished products?

What if I sold them at such a high price that it would be uneconomical for someone to buy a phone case just to recycle the carbon fibers? Is that a bad argument considering it might not require a lot of carbon fiber to make a nuclear weapon?

And no, I’m not a terrorist. Just trying to make a honest living. I love this world and I’d hate to see it nuked again.

#2

Have a look at: http://lawcustoms.wordpress.com/2012/04/27/exporting-carbon-fiber-products-from-the-united-states/.

We (in New Zealand) have to import all raw carbon fibre and we have used it to make parts for military projects. We must sign a declaration stating the end use and user. Plus we have had a few visits from the SIS (our version of the FBI and CIA) to check we aren’t up to anything dodgy and we call them when we have a odd request come in.

Call US customs (or like) and see what they say, don’t risk going to jail on the results from a internet forum site.

#3

Check out the following link: http://www.bis.doc.gov/policiesandregulations/advisoryopinions/oct25_2011_guidance.htm

You should not have any issues so long as you are using standard modulus (high strength) carbon fiber in your parts. As far as I am aware, the laws mainly focus on the specific strength and modulus of the carbon fibers i.e. strength/density and young’s modulus/density. If you try and export parts made with intermediate or high modulus carbon fiber you may have problems.

I don’t know of any laws regarding the sale of carbon fiber products within the US.

As far as your cost idea goes, I don’t think it will work since some ultra stiff carbon fibers cost hundreds of dollars per pound.

#4

At work, I’m the export focal, and deal with export classification quite often. Since your raw material isn’t used for a military part, the export jurisdiction falls under the US Department of Commerce. I’ll look up the ECCN and export restrictions for carbon fiber (although I suspect it will depend on the exact properties of the carbon fiber you’re dealing with).

If all you are exporting is raw material, look here: If you are exporting finished products, then the export classification will be different.

Start here:
http://www.bis.doc.gov/policiesandregulations/ear/index.htm

Raw materials are in category 1:
http://www.bis.doc.gov/policiesandregulations/ear/ccl1.pdf

Depending on your exact carbon material, check out these, in decreasing level of export control:

  • 1C010 “Fibrous or filamentary materials” as follows (see List of Items Controlled).
    Reason for Control: NS, NP, AT

  • 1C210 “Fibrous or filamentary materials” or prepregs, other than those controlled by 1C010.a, .b or .e, as follows (see List of Items Controlled).
    Reason for Control: NP, AT

  • 1C990 Fibrous and filamentary materials, not controlled by 1C010 or 1C210, for use in “composite” structures and with a specific modulus of 3.18 x 106m or greater and a specific tensile strength of 7.62 x 104m or greater.
    Reason for Control: AT

If your carbon material does not meet any of those categories, then your material is classified with an ECCN of EAR99.

For your information:
NS - National Security
NP - Nuclear Non-proliferation
AT - Anti-Terrorism

Based on commercially purchased carbon, for use in making wallet, I would guess that your carbon doesn’t meet any of those requirments in that document, and that it would be EAR99. If in fact it does not meet those requirements and it is EAR99, it will be a no license required (NLR) export. Even if you match the bottom category of 1C990, the only reason for control is AT, which means if you’re not exporting to one of the 5 terrorist supporting nations, then you don’t need an export license (NLR).

All of this information I listed is just for your information, to give you a very good starting point in export classification. DO NOT USE THIS INFORMATION AS FACT, please confirm yourself.

#5

lol blaw blaw blaw, if someone really has a beef with a CF wallet you are selling they have too much time on their hands…

#6

In the United States, export restrictions are taken very seriously. Exporting restricted items without a proper license can lead to severe fines and jail time.

#7

I didn’t think there were so many problems with CF pieces…
A contradiction into a union of states with a internal free arms trade.

#8

This stuff doesn’t apply to between states, only for export outside the US.