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State Dept. Expands Revised Processing of Commodity Jurisdiction Requests

Monday, November 18, 2013
Sandler, Travis & Rosenberg Trade Report

The State Department’s Directorate of Defense Trade Controls has announced that as of Nov. 14 it is reviewing newly submitted commodity jurisdiction requests that involve articles or services relating to U.S. Munitions List categories VI (surface vessels of war and special naval equipment), VII (ground vehicles), XII (materials and miscellaneous articles) and XX (submersible vessels and related articles) pursuant to the final rules transferring certain goods in these categories to the Commerce Control List. DDTC states that this change is necessary because it currently takes about 60 days to process a CJ, meaning final determinations for CJs submitted after Nov. 14 will not be issued until after the Jan. 6, 2014, effective date of the final rules. However, exporters and manufacturers are advised to continue using the current USML control criteria for items subject to the final rules until the new control criteria take effect on Jan. 6.

DDTC states that this change does not affect CJ requests that have already been submitted and are under review. It also does not relieve any exporter or manufacturer of its obligations to comply with any licensing and compliance requirements.

DDTC intends to implement similar policies for CJ requests for other USML categories under revision pursuant to the Export Control Reform Initiative 60 days prior to their effective dates.

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