U.S. Munitions List (USML)

By: Reid Whitten

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 situations.  Among the first test subjects are those who oversee ITAR compliance for manufacturers and exporters of aircraft and aircraft parts.  While these brave souls will be the front line of the ECR implementers, those in the ranks behind (looking at you, Military Vehicles and Naval Vessels) will do well to learn from their experience.
Continue Reading Export Control Reform Series Episode II: The First Change – Reevaluating your ITAR Aircraft Parts

By: Scott Maberry and Reid Whitten

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, 2013, the Administration notified Congress of the first in a series of amendments to the U.S. Munitions List.  The next day, March 8, 2013, the White House released Executive Order 13637 to update delegations of presidential authority over the administration of export and import controls.  Also on March 8, the White House issued a fact sheet on the implementation of export control reform.  These steps, though small, mark clear progress in the President’s Export Reform Initiative.
Continue Reading Streamlining the System: More Baby Steps Toward Reducing Export Compliance Burdens

By: Curt Dombek and Mark Jensen

On June 19, The U.S. Department of State, Directorate of Defense Trade Controls (DDTC) and U.S. Department of Commerce, Bureau of Industry and Security (BIS) proposed a joint, largely standardized definition of “specially designed” that would apply to items on both the Commerce Control List (CCL) and U.S. Munitions List (USML).  The definition represents a major step in the functional merger of the two lists.  Once implemented, it should ease the administrative burden of U.S. export compliance on companies whose work touches both areas and clarify the status of a large number of items.  One thing it will not do (and which may never be done) is remove ambiguity from the lists altogether.
Continue Reading All Together Now: A New Joint Definition of “Specially Designed”