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April 14, 2014 

Computer Issues Delay DDTC's Processing of Commodity Jurisdiction Requests

By Doug Jacobson and Michael Burton, Jacobson Burton PLLC

The State Department's Directorate of Defense Trade Controls (DDTC) has recently been experiencing problems with the computer system used to process Commodity Jurisdiction requests (CJs) submitted by industry. These technical issues have been causing delays in DDTC's processing CJs over the past few weeks.  

Today DDTC posted the following announcement confirming these delays:

 CJ Submissions: Due to technical issues, all new CJ submissions and those currently in process will be on hold until further notice. Updates regarding this web notice will be provided as new information is received. (04.14.14)
Over the past few years the time for DDTC to process and issue a CJ determination has fallen dramatically and most CJs are issued within 60 days after they are submitted. By contrast, as indicated in a GAO report issued in 2007, the median CJ processing time was 157.5 days in 2006 and 126 days in 2007.

CJ requests are submitted to DDTC when it is not clear whether a product, software or technical data is subject to the licensing jurisdiction of the International Traffic in Arms Regulations (ITAR) administered by DDTC or the Export Administration Regulations (EAR) administered by the U.S. Department of Commerce's Bureau of Industry and Security. The pending Export Control Control Reform process, which has already clarified many categories of the U.S. Munitions List and will address additional categories in the coming months, is expected to lead to a reduction in the number of CJs being submitted. 



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