Export Control Reform

Recent changes under export control reform.

Recent changes to International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) will affect companies that manufacture for the aircraft industry.

We already know that changes are coming to other Categories within the USML and CCL, if your category is not affected during this change, then now is the time to start learning from those companies that are going through the implementation of the regulations. Below is a summary of the regulations and what every company should be doing to prepare for October 15 implementation.

The DDTC final rule issued on Tuesday April 16, 2013 amends the ITAR categories VII (aircraft and related articles, XVII (classified articles, technical data and defense services not otherwise enumerated) and XXI (articles, technical data and defense services not otherwise enumerated). The final rule also creates a new category, XIX that will cover gas turbine engines and associated equipment.

The BIS final rule also issued on Tuesday April 16, 2013 (link to final rule) creates ten new 600 series Export Control Classification Numbers (ECCN) in order to provide an ECCN for those items being transferred from the USML.

There is a 180 day transition period until the date of publication and the effective date (October 15, 2013). During these 180 days exporters should take the following steps to ensure they implement the final rule in their companies:

  1. Review your product line and determine if any of your items will move from the USML to the CCL.
  2. Determine the new CCL classification and become familiar with the Export Administration Regulations (EAR).
  3. Develop a plan to draft and submit Commodity Jurisdictions for any items you are not able to determine if they have moved over to the CCL. Submit any Commodity Jurisdiction as soon as possible, as it is expected that the number of request will increase during this period.
  4. Determine if you have any open licenses or agreements that involved the items moving over to the CCL and determine if you need to submit a new license request through SNAP-R.
  5. Review your policies and procedures and modify your licensing determination, license application and license implementation procedures to accommodate for differences in DDTC and BIS licensing requirements.
  6. Update your training materials to include changes to your policies and procedures and the final rule.
  7. 7. Contact Trade Consulting Services for assistance in implementing the final rules.

We are here to help.

While other compliance service firms are trying to learn the EAR regulations, Trade Consulting Services has experience in both the ITAR and the EAR and can help you navigate the next steps to ensure your company complies with the regulations.

In addition to our knowledge of the regulations we provide:

  1. Convince;
  2. Cost Savings;
  3. Efficiency; and
  4. Peace of mind.

You can trust our consultants to help you understand and implement the EAR CCL, determine license exceptions, submit export license applications and Commodity Classification Requests.

Give us a call at 214-810-0204 or send us an email at [email protected] and let us know how we can help you.