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September 03, 2013 

DDTC Issues Notices on Commodity Jurisdiction Changes and Guidance to Prevent RWAs

The State Department's Directorate of Defense Trade Controls (DDTC) released two Industry Notices in the past week providing important information and guidance to exporters and manufacturers of defense articles.

Commodity Jurisdiction Policy Change

The first industry notice, published on August 30, 2013, states that due to the upcoming changes to the U.S. Munitions List (USML) arising from the export control reform (ECR) process, starting on September 1, 2013 DDTC will review newly submitted commodity jurisdiction (CJ) requests involving articles or services relating to USML Categories VIII (Aircraft and Related Articles) and XIX (Gas Turbine Engines and Associated Equipment) using the new version of the USML contained in the final rule that will take effect on October 15, 2013. 

The reason for this change is that the current CJ processing time is 60 days and thus CJs submitted after September 1, 2013 will not be issued until after the final ECR rule goes into effect.

DDTC's notice also notes that exporters and manufactures should continue using "the current control criteria" on the USML until the new rules go into effect on October 15, 2013.

The notice indicates that DDTC will implement similar 60-day policies for CJ requests submitted for other USML categories that will take in the coming months. For example, starting in November 2013, DDTC will begin processing CJs for USML Categories VI (Vessels of War and Special Naval Equipment), VII (Tanks and Military Vehicles), XIII (Auxiliary Military Equipment) and XX (Submersibles) under the new criteria, since the new USML categories will go into on January 6, 2014.

RWA Guidance

Today DDTC's Office of Licensing issued a notice advising exporters submitting licenses for defense articles of the reasons why cases were returned without action (RWA) last week. These reasons include:

  • Failure to provide a purchase order with the submission
  • Provided letter of intent [instead of] purchase order for Significant Military Equipment
  • Not all Party names and addresses were included in submission
  • Insufficient technical data submitted for technical review
  • Not following Firearms Guidelines regarding suppressors
  • Exporting CCL items on a DSP-5
DDTC noted that:
"All of these RWAs were preventable. Don’t be one of these people. RWAs waste time, ours and yours."
Exporters are reminded to use the checklists on DDTC's websites when submitting license applications and other authorization requests to DDTC.
 Our law clerk Andrew Azorsky contributed to this report.



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