How To Meet Rules of the Sky for Aircraft Exports

Schuyler "Rocky" Reidel

Schuyler "Rocky" Reidel

Schuyler is the founder and managing attorney for Reidel Law Firm. | How To Meet Rules of the Sky for Aircraft Exports

Sanctions have a secondary effect on those doing business with the country in question.

If Russia is one place you operate, you’ve likely noticed this in your dealing with civil aircraft sales.

The United States is one of the largest exporters of aircrafts, distantly followed by France. Although larger players like Boeing will still take a hit, the negative impact won’t be significant.

But what about in your case? And how do you remain compliant with our aviation export laws in the first place?

It’s time to explore these questions and much more, so let’s get started.

Changes to Aircraft Exports in 2022

Unless you’re living in a steel bunker without access to the news, you’ve probably read or heard about the sanctions on Russia. It’s influenced all industries, but you obviously care about the repercussions for aircraft exports.

Viewing it as the entrepreneur you are, a certain question may be floating around in your head.

“How do I mitigate risk to my business and still stay profitable?” Let’s explore this great question.

Recent Changes

There are two aviation updates that you should care about. Both come from the Bureau of Industry and Security (BIS), a wing of the U.S. Department of Commerce.

  1. Wide and stiff controls on aviation-related items destined for Russia (2/24/22)
  2. Similar controls on Belarus (3/2/2022)

Contained within this documentation is a new license requirement for specific aircraft or parts. And it’s not exclusive to planes made here.

It also applies to any aircraft “manufactured in a foreign country that includes more than 25% parts from the United States.”

For more information around this change, reach out to us.

Next, let’s look at an important step in the process.

Process for Exporting Aircraft

Exporting an aircraft from the United States starts with filing an Electronic Export Information (EEI). The actual submission is done through the Automated Export System (AES).

This is required in the case of an aviation sale to a foreign buyer where it’s permanently exported. It’s normally filed before the physical plane takes off for its new home.


Shifting gears, as related to non-sanctioned nations, are any licenses required to export aircraft from the U.S.?

Generally, they aren’t needed for most civil aircraft which fall under Export Administration Regulations (EAR) or U.S. economic sanctions.

But as mentioned earlier there are a few exceptions:

  • Countries under sanctions
  • Individuals on barred lists

In terms of individuals, the lists include barred entity, Denied Persons, and Specially Designated Nationals.

Obviously, there’s a bit more to the overall process, but it’s worth wrapping up on a positive note. Ready?

  • According to trade numbers, in February the U.S. exports of civilian aircraft and parts totaled $6.4 billion

This was an increase from the same time last year and should give you hope as a civilian aviation exporter.

Aircraft Exports and Reidel Law Firm

As experts in international trade law, we can help you handle the legal aspect of aircraft exports. In addition, our legal team can advise you on ways to shore up any gaps in:

  • Import Compliance
  • Export Compliance
  • Litigation before the Court of International Trade (Section 337, anti-dumping/countervailing, and other trade related cases)
  • Trade Compliance Audits and Training

A robust compliance program is necessary for any business engaged in international trade. Our International Trade Law division helps businesses both in Texas and around the world with understanding and complying with the many complex import and export regulations.

By effectively managing risks and maximizing opportunities for businesses we answer the needs of our clients wherever and whenever they arise.

Call Reidel Law Firm today at (832) 510-3292 or fill out our contact form to see how we can help your business expand internationally.

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