For the purposes of 15 CFR 740.15, do offshore oil drilling rigs / platforms qualify as Vessels?
Offshore drilling rigs and platforms do not constitute “vessels” for the purposes of License Exception AVS eligibility, as described in Section 740.15 of the Export Administration Regulations (EAR) (15 CFR Parts 730-774).
The items that are eligible for export or reexport under License Exception AVS are, for the most part, those necessary for the proper operation (e.g., propulsion, navigation) of an aircraft or vessel or those intended for use as plane or ship stores. The scope of items that may be necessary for the proper operation of an offshore drilling rig or platform (even one that is self-propelled) might well include platform stabilization and drilling or oil exploration equipment that would go well beyond the scope of items contemplated under License Exception AVS as eligible for export/reexport to, or on board, vessels and aircraft.
For additional information on the EAR requirements described in this e mail, you may wish to view the EAR on-line, at:
www.access.gpo.gov/bis/index.html. Should you have additional questions about the requirements in the EAR, you may wish to contact the Outreach and Educational Services Division, at: (202) 482-4811.