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Imminent Changes to the U.S. Munitions and Commerce Control Lists Require Attention

December 4, 2013

On January 6, 2014, the second tranche of rule changes under President Obama’s Export Control Reform (“ECR”) initiative will take effect.1  ECR’s purpose is to build “higher walls around fewer items” by transitioning relatively less sensitive articles from the United States Munitions List (“USML”) in the International Traffic in Arms Regulations (“ITAR”) to the Commerce Control List (“CCL”) in the Export Administration Regulations (“EAR”), and maintaining strict controls on USML items.  The January 6, 2014, changes relate primarily to military vehicles, naval vessels, and submersibles. 

The changes discussed here are the second step in a multi-phase reform effort by the U.S. Department of State (“DoS”), Directorate of Defense Trade Controls (“DDTC”) and the U.S. Department of Commerce (“DoC”), Bureau of Industry and Security (“BIS”).  Principal changes include updated definitions in the DDTC-administered ITAR and BIS-administered EAR, changes to the USML and CCL, and the creation of a shared export licensing authority between DDTC and BIS.  These amendments will have a significant impact on many defense industry manufacturers and exporters because they result in substantial changes to the jurisdiction and classification processes for a wide array of naval vessels, military vehicles, and miscellaneous equipment and materials.

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