Tel: (860) 651-8544

Archive for the ‘Export Control Reform’ Category.

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 […]

EAR/ITAR Definitions Rules

On June 3rd, the State and Commerce Departments released final rules revising export related definitions in the EAR and ITAR.  Definitions of export and re-export were harmonized across the two sets of regulations to ease the burden on exporters.  Additionally, definitions of release and retransfer were added to the ITAR, the latter of which is […]

Export Control Reform Timeline Change

On October 9th, 2015, DDTC amended the previously published Export Control Reform Initiative timeline, allowing exporters to use the full length (48 months) of previously obtained State Department licenses for items that have since transitioned to the EAR. Additionally, exporters are allowed one additional year to secure BIS licensing for agreements that contain either solely […]

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 […]

Special Comprehensive Licenses (SCL) Removed from EAR

On August 26th, the EAR was amended to remove Special Comprehensive Licenses (SCL) effective September 25, 2015. The major reason for this change was that BIS officials believed that SCLs were no longer necessary in light of Export Control Reform.  It had been concluded that individual licenses would offer exporters substantially the same benefits than […]

ITAR Amendment- Clarifying registration/licensing requirements for U.S. persons with foreign employer

The comment period recently closed for a proposed ITAR amendment that would clarify registration and licensing requirements for U.S. persons providing defense services on behalf of their foreign employer. The purpose of this clarification by the DDTC is to establish when U.S. persons are covered by licenses previously acquired by their foreign employer and if […]

Export Control Reform: Update and Recap

Export Control Reform: Update and Recap   Over the last 20 months, the State and Commerce Departments have published final rules for the transition of 15 categories.  Additionally, 3 more have had proposed rules published that are expected to be published in the final form in the coming months.  A few especially pertinent transition dates […]

Temporary Change to ITAR USML Category XI

On July 2nd, the State Department announced a temporary change in ITAR USML Category XI.  Due to confusing language prior to the change, some exporters did not realize that certain intelligence analytics software remained under the jurisdiction of ITAR USML Category XI. To end this confusion, a temporary revision to Category XI(b) was enacted on […]

Proposed Changes to USML Category XIV and USML Category XVIII

On June 17th, Commerce and State announced a proposed rule that would revise USML Categories XIV (toxicological agents) and XVIII (directed energy weapons). For USML Category XIV, items being moved to the jurisdiction of the EAR are “primarily of dissemination, detection, and protection, ‘equipment’ and related articles”. The new related ECCN will be 1X607. For […]

USML Category XII Proposed Revision-BIS Guidance on Infrared Detection Items

On May 5th, BIS published a proposed rule for the revision of USML Category XII.  This rule would result in the creation of new ECCNs 6×615 and 7×611 for military fire control, range finder, optical and guidance items. Additionally, controls on certain infrared detection items were increased.  On June 16th, BIS published a document providing […]