On October 15, 2013, the first set of final rules implementing the US Government’s Export Control Reform (ECR) Initiative took effect, reshaping the structure of US export controls. The effective date is based on an approximate 180-day period set forth in final rules published on April 16, 2013 by the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of State, Directorate of Defense Trade Controls (DDTC) (collectively the Agencies), amending the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), respectively. These parallel rules will move a significant number of items (i.e., commodities, technology, and software) from the US Munitions List (USML), maintained by DDTC, to the Commerce Control List (CCL), maintained by BIS. In order to implement the transition, the rules also create new structures to maintain tight controls over certain USML defense articles moved to the CCL while also integrating them into the EAR licensing regime.
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USA
October 19 2013
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Marion Rich
Director of Legal & Contractual Affairs
British Constructional Steelwork Assoc Ltd
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