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USML Category XII Proposed Revision

On February 19, the Commerce and State Departments published proposed revisions to USML Category XII and the EAR relating to the control of Fire Control, Lasers, Guidance and Control Equipment.   A previous version of the proposed rule was published on May 5, 2015; due to the comments received however, there was a complete re-draft for the current published version.  One of the major changes from the State’s first proposed rule to the current one is that “certain articles will be controlled based on the design intent of the manufacturer”, as frequently components can be used by more than one higher end assembly. Additionally, XII(x) was proposed, allowing items that are controlled by the EAR, but are to be used in/with the Category XII item to be licensing by the State Department, provided purchase documentation is submitted demonstrating this.

 There were also extensive revisions to EAR controls for Fire Control, Laser, Imaging, and Guidance and Control Equipment. The largest revision with this proposed rule is the creation of only one set of 600 ECCNs corresponding to USML Category XII (7×611), as opposed to the previously proposed rule which created 6×615 for military fire control, range finder, and optical items and 7×611 for military guidance and control items.  Under the current proposed rule, 7×611 would cover all items under USML Category XII.  Wilmarth & Associates will post a blog when the final rule has been issued.


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