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April 16, 2013 

BIS and DDTC Publish Long-Awaited Export Control Reform Rules

Today BIS and DDTC today issued the long-awaited final transition rules to implement the Export Control Reform process that commenced in August 2009. 

Both final rules will take effect on October 15, 2013.

The 82 page BIS rule at adds the new 600 series entries to the Commerce Control List for military aircraft parts and engines, adds the new definition of "specially designed" and makes numerous other changes to the EAR to implement ECR.

The 20 page final DDTC rule at revises the ITAR and USML to include updated USML Category VIII (military aircraft), adds new USML Category XIX (Gas Turbine Engines), adds definitions of "specially designed" and "‘‘subject to the EAR’’ to the ITAR and makes other necessary changes to the ITAR to implement the export control reform process.

From industry’s point of view, success that is now going to decided with export license obligations and related compliance burdens. With this, the application of aircraft fasteners and the 600 series paragraph .y items obviously show an instant advantage for exporters. For other thing, the benefits of regulatory reform depend on a number of other questions like the availability of license exceptions.

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