Name: Applied Materials: $252.5M over a question of origin — de minimis and dual origin
Uploaded: 2026-10-15T09:00:00+02:00
Duration: 9 min 45 s
Description: Matthew A. Bock walks through the EAR jurisdiction criteria, the de minimis rule and its three thresholds, then the Applied Materials case, where customs origin and export origin did not coincide.

Part 2/3 · 9 min 45. The video is in French.

What the video covers

00:00 "Subject to the EAR": five alternative criteria
02:30 The de minimis rule: three thresholds, two traps, a worked example
05:00 Applied Materials: a $252.5M civil penalty over a question of origin
08:30 One item, two origins: where customs and export controls diverge

Presentation by Matthew A. Bock, attorney (Bock Trade Law, Massachusetts), at the 16 September 2026 webinar of the Occitanie committee of the French Foreign Trade Advisors, where I spoke alongside him. The presentation is in French. It addresses US law and is general information, not legal advice. Published with the speaker's consent.

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Other parts

The four webinar chapters (Jan Holtzhäusser) →

Applied Materials: $252.5M over a question of origin — de minimis and dual origin

What the video covers

These questions come up every week in an export department.

Other parts

A sensitive operation in the pipeline?