Despite a 16-day shutdown, the government’s export control functions seem to be moving forward again. This is particularly helpful given this week’s implementation of the final rule for aircraft and related articles – a major step in President Obama’s Export Control Reform (ECR) initiative. As we have discussed extensively on this blog, the new rules became final on October 15. With this change, there are now revised versions of both the United States Munitions List (USML) and Commerce Control List (CCL). The CCL includes the new “600 series” of ECCNs which reflect items being moved over from the USML.
So far, only BIS has published a new version of the CCL on their site. To view the latest version of the USML, exporters are still required to look at the Federal Register notice from State. Here are the links:
Click here to view the new version of the Commerce Control List (CCL).
Click here to view the new version of the United States Munitions List (USML).
It’s also worth noting that both BIS and DDTC appear to be operating again, now that the government shutdown has ended. However, we can probably still expect to see longer-than-normal processing times for licenses and other requests as the agencies work to get through the backlog of cases that undoubtedly piled up during the shutdown.
Tom Reynolds is the Vice President of Operations for Export Solutions, a consultancy firm which specializes in ITAR and EAR compliance.