The State Department is following Commerce’s lead with reaching out to industry on the export control reform tools. As part of the Directorate of Defense Trade Controls (DDTC) outreach efforts for the initial implementation of Export Control Reform final rule published on April 16, 2013, DDTC has developed a new web-based decision tool that will assist users in understanding and applying the new rules and regulations.
This tool walks exporters through the questions necessary to help determine if your product is “specially designed” or if it falls under one of the exempted products under the definition.
Another tool establishing the order of review for your product is coming soon.
The “specially designed” tool is effective for exports on or after October 15, 2013. It applies only to commodities and software related to United States Munitions List (USML) categories that have been revised in accordance with the President’s Export Control Reform (ECR) initiative.
Tom Reynolds is the Vice President of Operations for Export Solutions, a consultancy firm which specializes in ITAR and EAR compliance.