Yes. An item is considered an export even if it is
- leaving the United States temporarily
- leaving the United State but is not for sale, (e.g. a gift)
- going to a wholly-owned U.S. subsidiary in a foreign country
- a foreign-origin item exported from the United States, transmitted or transshipped through the United States, or being returned from the United States to its foreign country of origin is considered an export.
There is, however, an exemption for certain temporary exports, so before temporarily exporting an item, check with your compliance officer to determine whether you are eligible for that exemption.