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Archive for September 2015

Cuba Restrictions Update

On September 21, the Treasury and Commerce Departments issued final rules regarding easing of restrictions on Cuba in light of recent policy changes. The Commerce Department rule revisions included amending the EAR’s Support for the Cuban People license exception, expanding the scale of the exception while still limiting items that are eligible to EAR99 goods […]

License Exception RPL: A Brief Overview

License Exception RPL (Servicing and Replacement of Parts)-EAR Part 740.10- authorizes items under EAR jurisdiction to be exported and reexported, as needed, for the one-for-one replacement of parts, components, accessories, and attachments. To utilize RPL, the items must have been lawfully exported and the original licensing authority must be confirmed by the exporter.  Additionally, the […]

Canadian Exemption Provision: An Overview

The Canadian Exemption Provision (22 CFR 126.5) is a State Department exemption for the export without a license for items whose end use is in Canada or the United States. To utilize this exemption, items must be covered under the ITAR, Canadian parties must be registered with the Canadian Controlled Goods (CCG) Registration Program, and […]

Category VIII Transition Period Ending

On October 15, 2013, many items previously under the jurisdiction of USML Category VIII were moved to the jurisdiction of the EAR. In light of this transitional period, a two year window was designated to allow companies with transitioned items to secure BIS licensing. On October 15, 2015, previously issued State Department licenses will no […]