In 21st century the U.S is the part of the new world
order where multipolarity is the foreign policy of geopolitical players
in international arena, so the United States requires new proactive
approaches and strategies to deal with constantly arising security
threats. The reality is that current national security structure is not
appropriate and qualified in solving contemporary national security
problems and might be in fact harmful if reorganizations of national
security apparatus would be ignored or delayed. According to the United
States Commission on National Security/ 21st Century “…most
troublesome is the lack of an overarching strategic framework… clear
goals and priorities are rarely set and budgets are prepared and
appropriated as they were during the Cold War..”
Along with the process of reorganization of national security
structure to meet the emerging threats of the new century, the President
directed in depth review and reformation of the U.S. export control
system in order to address the challenges of contemporary economic and
technological environment. Indeed the confusion exist due to difficulty
in identification which list the U.S. Munitions List (USML) or Commerce
Control List (CCL), administered by the Department of State and
Commerce respectively holds jurisdiction over the certain item
controlled. The ECR initiative is a long process which started in year
2009 by the presidential decision to review all seven agencies directly
involved in export control process. By implementing all three Phases of
reformation the administrations tries to create a single control list,
licensing agency as well as unified information technology system, and
enforcement coordination center. As of now in October 15, 2013 certain
proposed rules will take an effect and the changes to ITAR controls are
scheduled to be implemented by categories starting with Category VIII –
Aircraft and Associated Equipment and Category XIX – Gas Turbine
Engines and Associated Equipment. Furthermore, one of the most
significant changes is the addition in CCL of the new “600 series” which
will be controlling former USML items. The establishment of a new
series ought to bring simplification of export control system through
eliminating restrictions on exporting items by transferring them from
laws and regulations that govern military products and services under
the International Trafficking in Arms Regulations (ITAR) to the laws of
dual use items controlled by the Export Administration Regulations
(EAR).
About the Author:
Marina Truhan
International trade compliance expert with a focus on export compliance, denied party screening, export classification,
EAR, ITAR, deemed export and encryption items.
For additional details on changes to EAR and ITAR and how this important change may affect your organization
you can consult Intredex Export Compliance services.
Intredex assists companies with services such as restricted and denied party screening,
product export classification,
and with achieving the EAR (Export Administration Regulations) and ITAR compliance
with developing procedures for export transactions in alignment with the U.S. Government laws and regulations.
Great summary and article. Export control reform really brought several changes to USML and CCL and will keep bringing some more. In particular we have seen many types of the military ground vehicles, war vessels and aircrafts in fact were transferred from US Munitions List to Commerce Control List.
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