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Export Regulations Revised to Reflect Changes to Dual-Use Goods List

Wednesday, October 24, 2018
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule revising the Commerce Control List and corresponding parts of the Export Administration Regulations to implement changes made to the Wassenaar Arrangement’s List of Dual-Use Goods and Technologies at the December 2017 WA plenary meeting. Effective Oct. 24, this rule (1) revises 50 ECCNs, (2) adds license exception GBS eligibility to ECCN 3A001.i, (3) removes ECCNs 6A990 and 6E990, (4) corrects ECCN 3A991, and (5) revises ECCN 2B206 to maintain nuclear proliferation controls.

Shipments of items removed from license exception eligibility or eligibility for export, reexport, or transfer (in-country) without a license (NLR) as a result of this rule that were on dock for loading, on lighter, laden aboard an exporting carrier, or en route aboard a carrier to a port of export on Oct. 24 pursuant to actual orders for exports, reexports, or transfers to a foreign destination may proceed to that destination under the previous license exception eligibility or NLR so long as they have been exported, reexported, or transferred before Dec. 24. Any such items not actually exported, reexported, or transferred before midnight on Dec. 24 will require a license in accordance with this rule.

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