State and Commerce Propose USML- CCL Changes

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May 31, 2013

The U.S. State Department and the Department of Commerce's Bureau of Industry and Security (BIS) concurrently proposed rules shifting control of USML Category XV items to the Commerce Control List (CCL), regulated by the Export Administration Regulations (EAR).  The changes stem from an amended section of the 2013 National Defense Act that states satellites and related objects are no longer under the regulatory jurisdiction of the International Traffic in Arms Regulations (ITAR).  Under the proposed BIS rule, the new items would be covered by four 500 series ECCNS in CCL Category 9, which are described below.  Comments on the proposed rules are due by July 8, 2013.

• ECCN 9X515 – controls “space craft,” ground control systems/training simulators, radiation hardened microelectronic circuits, and other “space qualified parts”
• ECCN 9B515 – controls test, inspection, and production “equipment,” “specially designed” for the “production” or “development” of ECCN 9A515 commodities, equipment for testing, and environmental test chambers
• ECCN 9D515 – controls “software” designed for “development,” “production,” operation, installation, maintenance, repair, overhaul or refurbishing of 9A515 and 9B515 commodities   
• ECCN 9E515 – controls “technology” “required” for the “development,” “production,” operation, installation, maintenance, repair, and overhaul of 9A515, 9B515, or 9D515 items.

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