SUP-04Edition 1.0 · November 2026
Working Under a Supplier’s BIS License
Know what was authorized, what applies to you, and what happens next
A step-by-step method for non-US companies that receive EAR-controlled items under a licence held by someone else — to establish what the evidence shows, which conditions reach them, and when another authorization is needed.
What this guide settles
- What you hold is evidence, not the licence: a full copy, an extract, a notice, a number and an invoice with a DCS prove different things
- Identify the licensee first — a foreign principal party in interest shares responsibility — and read the scope where it lives, narrowed by conditions
- Outside the baseline is not automatically prohibited: test §750.7(c)(1), then NLR, licence exceptions or another authorization — and value tolerance is not quantity tolerance
- Expiry governs the initial licensed transaction, not every later one; conditions get an owner and end only on a documented basis
What you get
- The guide: explanations, method, conditions and limits
- Worked examples: what each piece of evidence proves, permitted changes under §750.7(c)(1), export rules in reexport and transfer contexts, a composite case, a commented real case (Al-Mashan) and ten pitfalls
- Tools printed in the guide: four templates, including a conditions register and a next-activity decision log, and a readiness check
- Sources with section references and their verification date
- Revisions included for 12 months
Printed tools: T1 · Licence evidence sheet · T2 · Authorization map · T3 · Conditions register · T4 · Next-activity decision log · Readiness check
Contents
- Before you start: scope and limits
- Why it matters to the recipient
- The rule in one page
- The licence, element by element
- The method in six steps
- Templates T1 to T4
- Ten pitfalls
- Case study: three requests
- Readiness check
What it does not cover
- Applying for your own reexport or transfer (in-country) licence
- A licence that cannot be found, or a supplier that does not answer
- Items integrated into a product made outside the United States
Assumed knowledge. How your items are classified, what a reexport and a transfer (in-country) are, and what you signed to support the licence, if anything.
Sample pages





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Where it connects
Export Control in Purchase Orders & Contracts
Working Under a Supplier’s BIS License reads the licence you received; Export Control in Purchase Orders & Contracts reads the clauses that transmit it — or go beyond it.
SUP-05Missing Licenses
Working Under a Supplier’s BIS License starts from licence evidence in hand; Missing Licenses starts when that evidence cannot be found.
ITAR-01Reading a DSP-5
Working Under a Supplier’s BIS License reconstructs an EAR authorization held by someone else; Reading a DSP-5 reads an ITAR licence’s scope, parties and provisos.
EAR-06EAR License Exceptions
Working Under a Supplier’s BIS License tells you when an activity falls outside the licence; EAR License Exceptions tests whether an exception covers it instead.
Part of a collection
Working Under a Supplier’s BIS License is one of the eight guides of Suppliers & Procurement (Manage Transactions), available together at €390 instead of €89 each.