Apple Trade Compliance

APPLE POLICY

As a global technology company, Apple is committed to complying with all applicable trade regulations in all countries in which we operate, including, but not limited to, all export and sanctions regulations. It is our policy to continually adhere to these regulations in all activities that we engage in. 

All Apple products qualify as mass market products and are not controlled on the Dual-Use Goods and Technologies List of the Wassenaar Arrangement. All Apple products are subject to the US Export Administration Regulations (EAR) when exported from the United States.

The classifications provided below are for the purposes of complying with the EAR for exports from the US and subsequent reexports. Apple products are not subject to Regional Stability (RS) controls and any parts and components of the products listed below are designated EAR99 or classified either under ECCN 5A992.c or an ECCN subject to anti-terrorism controls.


CLASSIFICATIONS

Apple makes no representation or warranty as to the accuracy or reliability of the classifications listed in this classification table. Any use of such classifications by the user, is without recourse to Apple Inc. and is at the users’ own risk. Apple is in no way responsible for any damages whether direct, consequential, incidental, or otherwise, suffered by the user as a result of using or relying upon such classifications, for any purpose whatsoever.

Apple complies with all reporting requirements for 5A992c/5D992c 742.15(b) items. The Apple retail products listed below do not fall within the descriptions provided in §§ 740.17(b)(2) or (b)(3)(iii) of the EAR.

APP (Adjusted Peak Performance) for all Apple computers is below 15 WT. 

PROHIBITED DESTINATIONS

The U.S. holds complete embargoes against North Korea and Syria.

The exportation, reexportation, sale or supply, directly or indirectly, from the United States, or by a U.S. person wherever located, of any Apple goods, software, technology (including technical data), or services to any of these countries is strictly prohibited without prior authorization by the U.S. Government. 

OFAC IRANIAN GENERAL LICENSE  D-2

On  September 23, 2022, OFAC issued Iranian General License D-2 (which superseded General License D-1, dated February 7, 2014), authorizing the exportation or reexportation, directly or indirectly, from the United States or by U.S. persons, wherever located, to persons in Iran of "certain services, software, and hardware incident to personal communications". General License D-2 enumerates certain categories authorized for export to non-prohibited end-users and end-uses in Iran. Some Apple goods and Apple software fall into these categories. For scope and further details, see General License D-2 and the Annex to General License D-2, available from OFAC's Iran Sanctions Resource Center at http://www.treasury.gov/resource-center/sanctions/Programs/pages/iran.aspx.

CUBA: SUPPORT FOR THE CUBAN PEOPLE

On January 16, 2015, BIS amended the Export Administration Regulations to create a new license exception Support For The Cuban People (SCP) and to authorize sales of the certain items covered under license exception Consumer Communication Devices (CCD). OFAC also published amendments to the Cuban Asset Control Regulations (CACR) authorizing export and reexports of items authorized for exports by BIS. License exceptions SCP and CCD enumerate certain categories authorized for export to non-prohibited end-users and end-uses in Cuba. Some Apple goods and Apple software fall into these categories. For scope and further details, see Cuba specific guidance on BIS website available at http://www.bis.doc.gov/index.php/policy-guidance/country-guidance/sanctioned-destinations/cuba and OFAC's Cuba Sanctions Resource  Center available at http://www.treasury.gov/resource-center/sanctions/Programs/pages/cuba.aspx.

CONSUMER COMMUNICATION DEVICES TO SUDAN

OFAC lifted sanctions against Sudan in 2017 due to improvements in cooperation between the U.S. and Sudanese governments. Today, Sudan is not subject to any economic sanctions administered by OFAC. 

In December 2020, Sudan was removed from the US State Department’s State Sponsors of Terrorism (SST) List and with that, conforming changes were implemented by BIS. For more information regarding this change, see https://www.bis.doc.gov/index.php/documents/regulations-docs/federal-register-notices/federal-register-2021/2710-86-fr-4929/file.

ENHANCED PROLIFERATION CONTROL INITIATIVE (EPCI)

It is prohibited to allow certain countries to use Apple products in the design, development, production or use of nuclear, missiles, and chemical and biological weapons and technology without proper authorization from the U.S. Government. This applies to all countries, EXCEPT Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy (includes San Marino and Holy See), Japan, Luxembourg, Netherlands, New Zealand, Norway, Portugal, Spain, Sweden, Türkiye, and United Kingdom.

DENIED PARTIES

Apple products may not be exported or re-exported to anyone on the U.S. Treasury Department’s list of Specially Designated Nationals or the U.S. Department of Commerce Denied Person’s List or Entity List, without required authorization.

SECTION 889 OF THE FY 2019 NATIONAL DEFENSE AUTHORIZATION ACT (NDAA)

Apple products are not "covered telecommunications equipment” or “critical technology” as defined in FAR 52.204-24 & 25 and do not incorporate or integrate any “covered telecommunications equipment.”

JAPANESE PARAMETER SHEET FOR APPLE PRODUCTS

Exporters in Japan may require a parameter sheet when exporting Apple’s hardware products from Japan. The parameter sheet for Apple hardware products is available at https://www.apple.com/legal/more-resources/docs/jp_hw.pdf. For more information on Japanese Export Controls and Parameter Sheets, visit CISTEC's web site at: http://www.cistec.or.jp/english/export/. 

APPLE AND BEATS PRODUCT INFORMATION SHEETS

MSDS/SDS are required for Chemicals and Substances. Apple's products and batteries are Articles and not subject to the MSDS/SDS requirements. However, Apple does provide product information sheets to facilitate shipments when a carrier requires MSDS/SDS. CHEMTREC, a provider of compliance related services, will distribute the Apple and Beats Product Information Sheets on Apple’s behalf. Apple and Beats Product Information Sheets are available at the following link: https://secure.chemtrec.com/lbrequest.html

To request the classification of an Apple or Beats product not listed in the Apple and Beats Product Information Sheets and for other questions related to the Product information sheet, please contact CHEMTREC.

CHEMTREC’s contact information is as follows:

• [email protected]
• 571-444-1833

For assistance with the US Export Administration Regulations or for help determining your export compliance obligations (including licensing requirements), visit the US Department of Commerce, Bureau of Industry and Security’s web page at http://www.bis.doc.gov/.

For questions about or requests for classifications of third party products, please contact the manufacturer directly.

Apple Inc.
Export Compliance Department
One Apple Park Way
Cupertino, CA 95014
USA

UN 38.3 BATTERY TEST SUMMARY

Effective January 1, 2020, section 38.3 of the UN Manual of Tests and Criteria requires that manufacturers and subsequent distributors of lithium cells and batteries manufactured after June 30, 2003, and products incorporating the same, make available test summaries for such cells and batteries. Countries in which Apple ships or sells batteries or products incorporating batteries may adopt this requirement into applicable regulations.

CHEMTREC, a provider of compliance services, will receive and respond to requests for battery test summaries on Apple’s behalf.

All requests for test summaries relating to Apple and Beats products should be directed to CHEMTREC.

CHEMTREC’s contact information is as follows:

• [email protected]
• 571-444-1833
• https://secure.chemtrec.com/lbrequest.html