If you haven’t already, it’s time to update your ITAR destination control statement on your commercial invoices.
As part of the Export Control Reform that implemented on October 15, 2013, a new destination control statement should be used on your export paperwork. This change is effective immediately. The Destination Control Statement is required on the Bill of Lading (BoL) or Air Way Bill (AWB) and other export documents (e.g. commercial invoice).
Here’s the new destination control statement from §123.9(b) of the ITAR:
“These commodities are authorized by the U.S. Government for export only to [country of ultimate destination] for use by [end-user] under [license or other approval number or exemption citation]. They may not be resold, diverted, transferred, or otherwise be disposed of, to any other country or to any person other than the authorized end-user or consignee(s), either in their original form or after being incorporated into other end-items, without first obtaining approval from the U.S. Department of State or use of an applicable exemption.”
It’s important to update your automated systems and paperwork to ensure that this new statement begins to appear on all of your company’s ITAR shipments.
Tom Reynolds is the Vice President of Operations for Export Solutions, a consultancy firm which specializes in ITAR and EAR compliance.