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Archive for the ‘Export Control Reform’ Category.

Agreement Amendment Requirements for USML Category XI and XV

November 10, 2017 will mark three years from the effective date of the Export Control Reform transition of USML Category XV and December 30, 2017 will mark three years from the effective date of the Export Control Reform transition of USML Category XI. It is vital that all agreements including items that have transitioned to the EAR be amended, or alternative licensing […]

CJs and CCATS

In instances where there is a question as to the classification or jurisdiction following the exporter’s self-classification, it is recommended that a State Department Commodity Jurisdiction (CJ) and/or a Commerce Department Classification Request (CCATS) be obtained for the items to be exported. Both classification submissions will allow for the confirmation of jurisdiction/classification, and thus allow […]

Classification/Jurisdiction of US Origin Items By a Foreign Entity

In certain cases, a foreign entity (i.e. foreign consignee, end user, etc.) may make a self-determination regarding the classification/jurisdiction of an item, including reclassifications based on Export Control Reform. If the U.S. exporter or manufacturer does not provide the foreign party with the classification, the foreign party is responsible for determining if the item is […]

Order of Review

Following Export Control Reform, many classifications for items determined prior to 2013 were no longer valid. To determine the current classification of an item, exporters should follow DDTC’s Order of Review. Exporters should first consider if the item is listed on the USML and if it falls within the definition of specially designed. If the […]

Spacecraft Regulations Revisions

DDTC and BIS released revisions to the Spacecraft regulations (USML Category XV) on January 10, 2017. The revised regulations will become effective on January 15th. Four categories of changes to the regulations were identified, including  (a) change in ITAR standards of control regarding aperture size for spacecraft; (b) the migration of the James Webb Space […]

Export Reminders for the Start of 2017

As the New Year begins, there are a few things to keep in mind to make sure you are in compliance with changing export regulations.  Revisions to USML Categories VIII, XII, XIII, XIV, XV, XVIII, and XIX (as well as associated CCL ECCNs) that have been finalized and published between July and November of 2016  will […]

USML Category VIII and XIX Revision

On November 21, Commerce and State published final rules revising and clarifying the items to be included in USML VIII and XIX (Military Aircraft/Gas Turbine Engines). These rules finalize proposed revisions that were published in February 2016, and will go into effect on December 31, 2016. The purpose of these revisions are to account for […]

New Destination Control Statement to be required on November 15th

As a reminder, the harmonized Destination Control Statement will be required by the State and Commerce Departments for export shipments starting on November 15.  Additionally, following implementation of this revision, the Destination Control Statement will only be required on commercial invoices (not on bill of lading, air waybill, etc. as is currently required). Items classified as […]

Category XIV (toxicological agents) and XVIII(directed energy weapons) Final Rule Published

On July 28, 2016 the Commerce and State Departments issued notices amending Category XIV (toxicological agents) and XVIII (directed energy weapons).  This transition will go into effect on December 21, 2016.  Category XIV, using guidance from the Department of Health and Human Services and Department of Agriculture, establishes a list of Tier 1 pathogens and […]

Export Control Reform: Update and Recap

Over the last 3 years, the State and Commerce Departments have proceeded in issuing proposed and final rules related to Export Control Reform.  Below is the current status of each category and a summary of the requirements for replacement/amendment of licenses for Category VIII/XIX transitioned items related to the termination of the transition period for […]