BIS Publishes Proposed Rule for Export Control Reform


On July 15, 2011, the Bureau of Industry and Security (“BIS”) published an important proposed rule regarding its plans for implementing the Export Control Reform Initiative. The proposed rule introduces the following:

A structure to the CCL that will facilitate the transfer of items currently controlled under the United States Munitions List (“USML”) to the Commerce Control List (“CCL”); A method for applying the new license exception STA, or Strategic Trade Authorization, to USML items that are transferred to the CCL; A miscellaneous ECCN classification to handle new technology and items transferred to the CCL from the USML until the proper CCL classification can be determined; A harmonized definition of “specially designed” to accommodate the transition of items from the USML to the CCL as well as to clarify the term as used in the CCL; and The transfer of some USML Category VII items to the CCL as a pilot of the new structure.

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