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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 are highlighted below.

 

2015 Transitions:

 

The Category VIII (Aircraft) and XIX (Turbine Engine) final rule was effective on October 15, 2013.  All licenses that provide for Category VIII items where all items have transitioned to the EAR must be transitioned to BIS licensing authority by October 14, 2015.

 

2016 Transitions:

 

The Category VI (Surface Vessels of War) and VII (Ground Vehicles) final rules were effective on January 6, 2014. All licenses that provide for Category VI and VII items where all items have transitioned to the EAR must be transitioned to BIS licensing authority by January 6, 2016.

 

The Category XV (Spacecraft) final rule was effective on November 10, 2014.  The transition period ends November 9, 2016.

 

The Category XI (Military Electronics) final rule was effective on December 30, 2014.  The transition period ends on December 29, 2016.

 

Proposed Rules:

Additionally, for Category XII (Fire Control) a proposed rule was published on May 5th. The comment period has recently closed, but the date of publication of the final rule is unknown at this time.

 

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