Print PDF

Practice Areas

Export Control List Changes for Military Vehicles and Vessels, Etc., Under Review

Friday, October 09, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security and the State Department are requesting no later than Dec. 8 comments that will aid in their review of the military vehicles, vessels of war, submersible vessels, oceanographic equipment, and auxiliary and miscellaneous military equipment that were moved from the U.S. Munitions List to the Commerce Control List effective Jan. 6, 2014. These reviews aim to ensure that the descriptions of these items on the CCL and USML are clear, do not inadvertently control items in normal commercial use, account for technological developments and properly implement the national security and foreign policy objectives of the Export Control Reform Initiative.

BIS is soliciting comments on the clarity, usability and any other matters related to implementation of the 600 series Export Control Classification Numbers that control the following items, as well as certain items related thereto: military vehicles (ECCNs 0A606, 0B606, 0C606, 0D606 and 0E606); vessels of war (ECCNs 8A609, 8B609, 8C609, 8D609 and 8E609); submersible vessels and oceanographic equipment (ECCNs 8A620, 8B620, 8D620 and 8E620); and auxiliary and miscellaneous military equipment (ECCNs 0A617, 0B617, 0C617, 0D617 and 0E617). BIS states that it will make any changes to the CCL that it determines are necessary to complement revisions to the USML. BIS is also seeking comments on how to improve the implementation of the 600 series ECCNs.

Concurrently, State is seeking comments on the condition and efficacy of the revised USML categories VI (surface vessels of war and special naval equipment), VII (ground vehicles), XIII (materials and miscellaneous articles), and XX (submersible vessels and related articles) and whether they are meeting the ECR objectives for the list revisions. In particular, State is interested in comments on the following topics as they relate to these categories.

- emerging and new technologies that are appropriately controlled by one of these categories but are not currently described in these categories or are not described with sufficient clarity

- defense articles that are described in these categories but have entered into normal commercial use since the most recent revisions to the category at issue

- defense articles for which commercial use is proposed, intended or anticipated in the next five years

- drafting or other technical issues in the text of either of the referenced categories

To get news like this in your inbox daily, subscribe to the Sandler, Travis & Rosenberg Trade Report.

Customs & International Headlines