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Export Control Regulations Amended to Reflect Missile Technology Regime Changes

Wednesday, April 08, 2015
Sandler, Travis & Rosenberg Trade Report

The Bureau of Industry and Security has issued a final rule that, effective April 7, amends the Export Administration Regulations to reflect changes to the Missile Technology Control Regime annex that were agreed to by MTCR member countries in 2014. This rule also makes three conforming changes to correlate the Commerce Control List with the current MTCR annex. This rule revises Export Control Classification Numbers 1C111, 3A101, 9A106, 9A110, 9A604 and 9A610 to implement these changes.

The MTCR is an export control arrangement among 34 nations, including most of the world’s suppliers of advanced missiles and missile-related equipment, materials, software and technology. The regime establishes a common list of controlled items (the annex) and a common export control policy (the guidelines) that member countries implement in accordance with their national export controls. The MTCR seeks to limit the risk of proliferation of weapons of mass destruction by controlling exports of goods and technologies that could make a contribution to delivery systems (other than manned aircraft) for such weapons.

Shipments of items removed from eligibility for a license exception or export or reexport without a license (NLR) as a result of this rule that were on dock for loading, on lighter, laden aboard an exporting or reexporting carrier, or en route aboard a carrier to a port of export or reexport on April 8 pursuant to actual orders for export or reexport to a foreign destination may proceed to that destination under the previous eligibility for a license exception or NLR so long as they are exported or reexported before May 8. Any such items not actually exported or reexported before midnight on May 8 will require a license in accordance with this rule.

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