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BIS Expands, Clarifies Export Controls on Certain Products

Tuesday, December 23, 2014
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued two final rules (i) clarifying U.S. export controls on certain products and (ii) expanding controls on certain electronic commodities, expanding license requirements for exports and re-exports to Hong Kong, and responding to an inquiry regarding the proposed export control classification of certain commodities.

Clarification of Certain Export Controls. The first rule revises six “600 series” Export Control Classification Numbers effective Dec. 30 to clarify that they do not control certain basic parts, components, accessories and attachments because those items are controlled in a new ECCN created by a July 1 rule that will enter into force Dec. 30. The rule also removes controls on certain monolithic microwave integrated circuit power amplifiers and discrete microwave transistors and related technology because two other rules published after July 1 already provide appropriate controls on those items.

In addition, BIS is clarifying the application of “specially designed” to controls published on July 1 that would apply to printed circuit boards, populated circuit card assemblies and multichip modules to reduce the possibility of confusion. Lastly, the rule revises three of the amendatory instructions in the July 1 final rule to avoid negating changes to the Export Administration Regulations that became effective after that date.

Expansion of Certain Export Controls. The second rule amends the EAR to expand national security controls on certain electronic commodities controlled on the Commerce Control List and limit license exceptions for these items. The rule also responds to public comments regarding the proper export control classification of certain electronic commodities and a type of radar and expands license requirements for exports and re-exports to Hong Kong of items controlled for national security reasons.

This rule is effective Dec. 23, with the exception of the revision of the related controls paragraph under the list of items controlled section in ECCN 3E001, which will enter into force Dec. 30.

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