Given that Export Control Reform (ECR) has finally reached phase two — the implementation phase — of a planned three-phase process, the question on the minds of most business leaders should be, “How does this affect my bottom line?”
First, it could be quite painful for companies, especially tier-two and tier-three manufacturers, to implement the reforms in the near term. Yet, most agree that updated US export control policies can be beneficial to companies that export both arms and dual-use items in the long term. As they say, no pain, no gain.
On April 16, 2013, as part of the Obama administration’s ECR initiative, the Departments of State and Commerce issued new rules regarding the licensing of items for export controlled within Category VIII (Aircraft and Related Articles) and Category XIX (Gas Turbine Engines) of the International Traffic and Arms Regulations (ITAR). These items are now captured in Export Control Classification Numbers 9A610 and 9A619 of the Export Administration Regulations (EAR). Items once licensed by State will now be captured on the Commerce Department’s Commerce Control List (CCL) and may be eligible for new licensing