Export Compliance

Live in the Field—an Export Compliance Q&A with SparkFun Electronics

At the Export Compliance Journal, we’re passionate about sharing insight from the trade and export compliance community, which is why we were thrilled to speak with Paul Robinson, Director of Support at SparkFun Electronics.

As an online retailer whose mission is to sell components for electronic projects, and make the world of electronics fun and accessible for everyone, you can imagine the key role export compliance plays in SparkFun’s day-to-day-operations. And it’s no easy task given that electronic components feature so prominently in the world of controlled goods, and that approximately 40% of SparkFun’s business is international.

We welcome Paul and thank him for taking the time to answer a few questions about some of the export compliance challenges his team faces every day, and the steps they’ve taken to overcome them.

Question
The company was founded in 2003—at what point did you realize that complying with trade and export regulations was more than just a “should do” but a ”must do?”

Answer
We got a call in 2010 from an investigator asking about some electronics that we had sold to a customer in Singapore. From there, the Singaporean customer was apparently sending them to Iran. We already had basic knowledge about the “lists to check,” but no understanding of anything more in-depth regarding export control.

Question
And now you use Visual Compliance™–Restricted Party Screening software—was there a reason why you decided to automate this part of the compliance process?

Answer
We decided to use screening software to take the development load off our employees. Checking the lists ourselves was proving to be complicated and time consuming. We decided to use the professional service to allow us to focus on the things we’re good at.

Question
How has automating the screening process impacted the way in which you conduct business?

Answer
Visual Compliance has helped us breathe a bit easier by making sure we won’t accidentally ship to someone we shouldn’t. It does trigger false positives that need to be followed up on before we can continue, but fortunately, the number of true hits we get is very low. There have only been a handful of entities we’ve had to decline to do business with.

Question
How has having to comply with export and trade regulations affected any business decisions? For example, are there products that you’d like to carry but decided not to for export compliance reasons?

Answer
We now get all product Export Classification Control Numbers (ECCN) early on in the research process. We’ve only ever had to reject one product for export control issues, a specialized camera that would have required more regulation than we wanted to deal with.

Question
Given that many of the products and technologies you sell are considered “dual use” (e.g., technology that can be used for both peaceful and military aims) are there any particular products that are under heavier scrutiny from an internal perspective (i.e., increased due diligence/documentation)? Or are all products treated the same?

Answer
We aim to sell products that are relatively lightly controlled, if at all. Most of our approximately 150 non-EAR99¹ products are only restricted for anti-terrorism, with approximately five products that have heavier controls. We inform customers before a purchase if a product has controls so they know the process will take a bit longer.

Question
Do you have a dedicated compliance team in place?

Answer
Our compliance is currently handled by our Customer Support team. As the workload increases, I would expect a dedicated department within the next 2-3 years.

Question
Do you educate your staff on the importance of trade and export compliance?

Answer
We make pretty big deal of it. The Customer Support department is the most aware of the daily ins-and-outs, but the entire company has been made well aware of the general requirements and knows to ask us if there are any questions.

About SparkFun Electronics
SparkFun is an online retail store that sells the bits and pieces to make electronics projects possible. No matter what the vision is, our products and resources are designed to make the world of electronics more accessible to the average person. In addition to products, SparkFun, through their Department of Education, offers classes and online tutorials designed to help educate individuals in the wonderful world of embedded electronics. Their ever-growing product catalog boasts over 3,500 components and widgets designed to help people unleash their inner inventor.

1. EAR99 is a classification for an item. It indicates that a particular item is subject to the Export Administration Regulations (EAR), but not listed with a specific Export Control Classification Number (ECCN) on the Commerce Control List (CCL).