We're going to be buying some products from the USA (essentially computer main boards), which are then integrated (with a number of other things from various parts of the world), and then shipped off to an offshore customer. The supplier of the main part of the unit has the following in their terms and conditions of sale,
That is all fine, basically the USA doesn't want people to act as agents to buy in one country and then export to a country or entity on their embargoes lists. No problem, the customer is not in one of those countries and in not on the restricted entities lists. Stanford has a nice list of export controlled countries as well as additional information around the subject.The United States Export Administration regulations prohibit export, reexport, transfer, and transshipment to restricted
countries or entities.
Once we sell it there is always the chance that it gets exported from the customer to another country, so what I am trying to figure out is the following,
- Does the USA export license apply to products where value has been added before export?
- Do I need to license the product under the same terms?
- Are there any similar South African license conditions for exports which may apply?