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First Wave of Export Control Reforms Effective Today
October 15, 2013


The first in a series of Export Control Reforms (ECR) takes effect today, despite the fact that the Federal Government remains closed.  The changes, which were published in April of this year by the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) and U.S. Department of Commerce’s Bureau of Industry and Security (BIS), transfer certain items from the U.S. Munitions List (USML) to the Commerce Control List (CCL).  This means that some articles will no longer be reviewed or licensed by the State Department, but may still be subject to licensing review under Department of Commerce regulations.

The DDTC Final Rule makes changes to USML Categories VIII (Aircraft and Related Articles), XVII (Classified Articles, Technical Data, and Defense Not Otherwise Enumerated), and XXI (Articles, Technical Data, and Defense Not Otherwise Enumerated) and adds USML Category XIX (Gas Turbines Engines and Associated Equipment).  Additionally, the Final Rule provides definitions for terms such as “specially designed,” and creates new licensing procedures for exporting items with defense articles subject to the Export Administration Regulations (EAR).  The BIS Final Rule implements ECR initiative changes by adding ten 600-series ECCNs to control munitions items that are transferred from the USML to the CCL.

For more information, please continue to visit www.barnesrichardson.com or contact a Barnes/Richardson attorney.

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