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Agencies Examine How Export Control Reform Changes are Working

Monday, March 02, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security and the State Department are inviting comments through May 1 on the first revisions made to the Commerce Control List and the U.S. Munitions List as a result of the Export Control Reform Initiative, which involved military aircraft, military gas turbine engines and related items.

ECR has resulted in the transfer to the CCL of items that the president has determined do not warrant control on the USML. The first rules implementing this initiative implemented revisions to USML categories VIII (aircraft and related items) and XIX (gas turbine engines and related items) as well as the 600 series Export Control Classification Numbers 9A610, 9B610, 9C610, 9D610 and 9E610 (aircraft and related items) and 9A619, 9B619, 9C619, 9D619 and 9E619 (gas turbine engines and related items).

BIS is now seeking input on the clarity and usability of, and any other matters related to, the implementation of these ECCNs. Similarly, State is accepting comments on the condition and efficacy of revised categories VIII and XIX and whether they are meeting the ECR objectives for the list revisions. BIS states that the aim of these reviews is to ensure that the revised USML controls 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 reform effort. Similar reviews are anticipated for each revised USML category.

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