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Export Control Reform-USML Category VIII Transition of Agreements and Licenses

On October 15, 2013, many items previously under the jurisdiction of USML Category VIII were transitioned to the jurisdiction of the EAR as part of Export Control Reform. 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 licenses will no longer be valid for these items, provided the license does not also cover items that did not transition or whose two year transition period has not yet expired (i.e. USML Category XI, IV, etc.).  Additionally, for MLAs/TAAs containing solely transitioning items, the agreement is valid for two years after transition or expiration of the agreement (if it expires prior to October 15, 2015).  If the MLA/TAA contains both transitioning and non-transitioning items, the two year window starts with the transitioning of the agreement’s last USML category.

 

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