Initial Provisions of Export Control Reform Become Effective October 15th - Steps to Take to Prepare for Export Control Reform
Contact: Thomas B. Mcvey; Williams Mullen (North Carolina & Virginia, USA)
On October 15, 2013 the first major series of amendments under the Export Control Reform will go into effect. Every exporter should be aware of these amendments and have a plan to prepare for these changes.
Background. Under the Export Control Reform, the Obama Administration is revising portions of the International Traffic In Arms Regulations (“ITAR”) and the Export Administration Regulations (“EAR”) to streamline and rationalize the U.S. export laws. As part of this process, the Directorate of Defense Trade Controls (“DDTC”) is transferring certain less sensitive items from the U.S. Munitions List (“USML”) to the newly created “Series 600” on the Commerce Control List (“CCL”) maintained by the Bureau of Industry and Security (“BIS”), and the agencies are adopting a number of additional changes to the ITAR and EAR. The Administration has promulgated a series of proposed regulations over the past three years leading up to these amendments, including proposed revisions to the various Categories of the USML. It is planned that these proposed changes will be finalized and go into effect on a rolling basis over the next twelve months commencing on October 15, 2013.
