Configuring Classification for Reexport Control

In delivery Customizing for SAP GTS, two country groups are provided for reexport control based on the EAR.

• USREX_CRIT Critical Countries for U.S. Re-Export
• USREX_UNCR Non-Critical Countries for U.S. Re-Export

The members of country group USREX_CRIT are Cuba, Iran, North Korea, Sudan, and Syria. Country group USREX_UNCR comprises all other countries except the United States.

The two country groups essentially represent the two de minimis rules defined in Part 734 of the EAR. The percentage for the maximum value share of U.S. origin content classified under one or several ECCNs has been entered in the Maximum Percentage field (SAP Global Trade Services, edition for SAP HANA → Compliance Management → Re-Export → Configure Country Group of Legal Regulation for Re-Export).

In addition to the percentage, one of four possible system reactions on the lack of price information in the product master data have to be selected in the Calculation Reaction field. These indicators also determine the source of product prices.

Product prices can either be maintained manually in the product master data on the Re-Export tab or be transferred from the feeder system. If the feeder system is the source, the prices are displayed on the Prices and Values tab.

The valuation of products is required for a reexport calculation that the system can carry out based on the bill of material (BOM) of a finished product. In this calculation, the system determines the total value of all components that could be dual-use items of U.S. origin. When checking the line item of an export document, the system calculates the share of this value in the actual sales price of the finished product. Depending on the country of destination, the system then applies a de minimis rule. If the value share of the dual-use items of U.S. origin is equal to, or less than 25 and 10 percent respectively, the finished product is not subject to the EAR.

If the legal regulation USREX or a customer-specific copy is active for legal control, users can maintain data for EAR-based reexport control on the Re-Export tab of the product master. The system uses this additional information primarily in reexport calculation for finished products.

If product prices are transferred from the feeder system on a regular basis, this additional master data maintenance will not be needed for most of the products. After an initial reexport calculation, the system anyway creates entries for both country groups in the product master data of the main part of the BOM, and adds the result of this calculation in the Calculated Hardware Share field. New reexport calculations update the master data.

Software and technology of U.S. origin classified under various ECCNs might not figure in the BOMs of the finished products to be exported. In such cases, the value of this software and technology can be maintained manually in the Predefined Software Share and Predefined Technology Share fields respectively.

The country of origin of a product plays no part in reexport control in SAP GTS. In reexport calculation, the system considers every product classified under an ECCN as originating in the United States.