A Changing Landscape for US Importers of Defense Articles

ATF revises US Munitions Import List and extends term for import permits.

On March 27, 2014, the US Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) published revisions to the US Munitions Import List (USMIL) as an interim final rule (IFR) effective April 28, 2014. The rule reflects ATF’s first substantive revisions to articles controlled under the USMIL since early 2013 when Executive Order 13637 and a related final rule decoupled controls on permanent imports of defense articles from other defense controls. Public comments on the IFR must be submitted by June 25, 2014. In addition, on April 8, 2014, a new ATF final rule took effect extending the term of permanent import permits for articles subject to the USMIL from one year to two years. These USMIL changes may significantly impact US importers of certain defense articles and make compliance more challenging, particularly in the larger context of the President’s Export Control Reform Initiative (ECR) and changes to controls on the export and temporary import of defense articles.

USMIL: Fewer Articles, More Specificity -

The USMIL is the official list of defense articles and defense services controlled by ATF for permanent import into the US. Importers of such items must register in advance with ATF and obtain a permit for the items to be imported, unless the transaction qualifies for a permit exception. The USMIL divides covered articles into numbered categories, and provides notes for additional context and reference.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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