ECR Export Control Reform Consulting

With ECR Export Control Reform, The International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) are changing, and this will affect businesses, especially those that manufacture components, systems or provide service for the aircraft industry.

This reform, also known as ECR Export Control Reform is a regulatory adjustment moving certain items and categories from listings in the USML (United States Munitions List) over to the CCL (Commerce Control List).  Now is the time to start preparing for the implementation of these new regulations.

Effective October 15, 2013

The Directorate of Defense Trade Control (DDTC) final rule issued on Tuesday April 16, 2013 amends the International Traffic in Arms Regulations (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 Bureau of Industry Security (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.  This will directly be applied through ECR Export Control Reform.

There is a 180 day transition period until the date of publication and the effective date (October 15, 2013). During these 180 days Export Compliance Officers (ECO) 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 under ECR Export Control Reform.

2. Determine the new CCL classification and become familiar with the Export Administration Regulations (EAR).

3. 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.

4. 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.

5. 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.

6. Update your ITAR & Export Compliance Program and any relevant training materials to include changes to your policies and procedures based on these changes.

7. Contact CVG Strategy for assistance in implementation and support on ECR Export Control Reform.

Kevin Gholston

Kevin Gholston

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