US Munitions List

News & Analysis as of

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...more

New Export Control Changes Affect Naval Warfare and Ground Vehicles

Second phase of the Export Control Reform Initiative allows certain U.S. industries to fall into categories that may make them more attractive to foreign buyers. On January 6, the Obama administration reached another...more

It’s Time For Ground Vehicle and Related Commodities Manufacturers to Embrace Export Control Reform

The Arms Export Control Act (AECA) requires the President of the United States to periodically review controls set for munitions on the United States Munitions List (USML). If the controls no longer remain warranted, the...more

ECR Series Episode VII: Livin’ in a Materials World – Changes to USML Category XIII

If you manufacture or export Auxiliary Military Equipment controlled under Category XIII of the U.S. Munitions List, you may rightly consider the category number unlucky. The current scope of Category XIII controls is broad...more

Export Control Changes Affecting Aircraft Industry Take Effect

New rules allow some aircraft-related items to fall into categories that may make them more attractive to foreign buyers. On October 15, the Obama Administration reached an important milestone of the president’s Export...more

What U.S. and Chinese companies need to know about U.S. export control laws applicable to China

According to a recently published report of the U.S. Congressional Research Service, the United States and the People’s Republic of China (‘China’) expanded economic ties substantially over the past three decades. Total...more

First Round of Export Control Reform In Effect Beginning October 15

Seems like all my free moments are on a plane. This flight in particular is an 8 hour flight — the inflight entertainment and the light controls are not working! This gives me time to reflect on Export Control Reform. With...more

ECR Series Episode VI: The One With Ewoks (And New Rules On Satellites)

This fall, the U.S. Government will finish considering public comments on its draft revision of U.S. Munitions List Category XV, which covers “Spacecraft Systems and Related Articles.” By the end of 2013 (unless delayed by...more

Global Connection - October 2013: Export Control Reform: Ready, Set, Go

For the past several decades, and especially since the heightened security enforcement in international trade, the global business community has railed against the complex, overlapping U.S. export controls laws and...more

Fixing a Broken Brokering Definition: DDTC Eases ITAR’s Regulatory Burden for Brokers and Brokering Activities

On August 26, 2013, in yet another move geared toward streamlining the U.S. export control regulatory landscape, the U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) published its long-awaited interim...more

Export Control Reforms Leads to Changes in Permanent Import Regime of Defense Articles and Services

In light of the upcoming changes associated with the Export Control Reform Initiative, the Department of Justice’s Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) issued a final rule in April 22, 2013, which amends...more

Export Control Reform Series Episode III: Harmonizing EAR Exceptions and ITAR Exemptions

In Episode I and Episode II of this series, we discussed some key points of U.S. Export Control Reform and took you through a step-by-step reclassification analysis of parts and components transitioning from the USML to the...more

Export Control Reform Series Episode II: The First Change – Reevaluating your ITAR Aircraft Parts

In Episode I: The Basics we noted that U.S. Export Control Reform may be causing confusion and consternation among those who will have to take the first theoretical rule changes and apply them in real and practical...more

Major Changes to U.S. Export Laws Go into Effect October 15, 2013: Is Your Company Ready?

New rules implementing export control reforms become effective October 15, 2013. The keystone of these reform efforts is to transfer jurisdiction of less sensitive military items currently controlled under the International...more

President Obama's Export Control Reform Initiative Continues with Final Revisions to Four U.S. Munitions List Categories and...

On July 8, 2013, the U.S. Departments of State and Commerce published final rules (78 Fed. Reg. 40892 and 40922), effective in 180 days (January 6, 2014), transferring export control jurisdiction over certain items previously...more

Changes to Munitions List, Commerce Control List go into effect in October, and more change is in the works – are you ready?

The Department of State and the Department of Commerce have issued final rules detailing changes to the classification of certain aircraft and gas turbine engines under Categories VIII and XIX, respectively, of the United...more

Status of Key Aspects of Export Control Reform

On April 16, 2013, the State Department and the Commerce Department published the first set of final rules in the Federal Register to implement the Obama administration’s Export Control Reform Initiative. The State Department...more

U.S. Export Control Reform To Move Wide Array Of Aircraft Parts Off The Munitions List But Still Prohibit Many Of Them From Being...

The U.S. Department of State, in response to the President’s Export Control Reform Initiative, published final rules in the Federal Register on April 16, 2013 moving export control jurisdiction from the State Department to...more

Export Control Reform to Move Wide Array of Aircraft Parts off the Munitions List

The Departments of State and Commerce published final rules in the Federal Register on April 16, 2013, moving export control jurisdiction from the State Department to the Commerce Department for a wide range of aircraft and...more

International Trade & Compliance - April 2013

The U.S. State and Commerce Departments have published amendments to the International Traffic in Arms Regulations (“ITAR”) and Export Administration Regulations (“EAR”) as a major step in implementing changes to export...more

The Jury Gets To Decide Whether All The Elements Of A Crime Have Been Proven, Even If One Of Them Is Really Complicated

Many white-collar cases start the same way - a person is an entrepreneur. He has a vision for a business he'd like to build. He wants to do great things and reform an industry....more

Streamlining the System: More Baby Steps Toward Reducing Export Compliance Burdens

Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more

Short Wins - A Remand In An Export Control Case

There's only one published win in the last week for a criminal defendant in our federal circuit courts. Gotta love a good case involving the Munitions List....more

Obama Administration Moves Forward With Export Control Reform

On March 7 and 8, 2013, President Obama took two important steps to further U.S. export control reform. First, the President notified Congress of the proposed transfer of certain items relating to aircraft and gas turbine...more

Fewer Military Controls and Streamlined Licensing for Exporters Are Expected: Are You in Compliance?

On Friday, March 8, 2013, the White House announced two important steps by the Administration to further its export control reform effort, which are expected to simplify licensing requirements for less sensitive items and...more

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