March has been a very busy month for US export control reform. On March 8, President Obama signed a new Executive Order that updates delegated presidential authorities over the administration of certain export and import controls. The Administration also announced that it had notified Congress on March 7th about its proposed export control changes for aircraft and gas turbine engines. These changes are very important because they involve transferring certain parts and components from the ITAR-controlled United States Munitions List (USML) to the Commerce Control List (CCL). This transfer will lead to a more streamlined export control process, which will make it easier for companies to export items to US allies, helping to boost sales and increase US competitiveness.
While the changes are a significant step forward in export control reform, there will be many challenges in managing the transition. After a 30-day review period in Congress, the final rules will be published, to be followed by a 180-day transition period. In the meantime, aerospace and defense organizations need to consider how the changes impact their current export compliance plans, especially in the area of user education. Organizations will need to make some decisions about how to educate users in the proper classification of export-controlled items, given that some items will be on the USML and others on the CCL.
As a first step, you can review some of the recent articles about the latest export control reforms, including:
- President’s Export Control Reform Initiative on export.gov
- Aerospace Industries Association export control reform fact sheet
- SpacePolicyOnline.com article on export reform
- DefenseNews article on USML changes
We also encourage you to attend the webcast US Export Controls & Defense Trade Controls Program: What You Need to Know in 2013. This two-hour live webcast brings together export-control experts who will discuss all of the latest export control changes (including the USML reform), and will provide best practices for managing the risk. As one of the speakers at this event, I will be providing real-life examples of how TITUS customers use our solutions to identify and protect technical data as part of an export control compliance program. This webinar is normally $299 per person, but you can register for the deeply discounted rate of $25 courtesy of TITUS.