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Tuesday, July 30, 2013

Moving Control of Certain Military Ground Vehicles from USML to CCL

On July 8, BIS published revisions to the Export Administration Regulations. Changes were regarding various categories of vehicles including Military Vehicles; Vessels of War; Submersible Vessels, Oceanographic Equipment as well as Relate, Auxiliary and Miscellaneous Items that are no longer considered to be under the jurisdiction of the USML of the Department of State and moved to CCL – the Department of Commerce. Furthermore, the revision identifies new ECCN’s of “600 series” created by movement of certain items within the Commerce Control List. The final rule will take an effect on January 6, 2014, so there is plenty of time to identify, comprehend and get used to all changes associated with implementation of the rule in particular and ECR initiative in general.
According to the Federal Register / Vol. 78, No. 130 / Monday, July 8, 2013 / Rules and Regulations, following revisions were made in Category 0—Nuclear Materials, Facilities, and Equipment [and Miscellaneous Items], Category 8—Marine and Category 9 —Aerospace and Propulsion of the  Supplement No. 1 to part 774 of the CCL. For the convenience of interested parties, changes related to some of the modified and created ECCNs are listed below, note that they are mostly in summarized format:
1.ECCN  0A018 -  Items on the Wassenaar Munitions List is amended by adding a sentence to the end of the Related Controls paragraph in the List of Items Controlled section and removing and reserving paragraph .a in the Items paragraph of the List of Items Controlled section.
2. Addition of  ECCNs 0A606 and 0A617 between ECCNs 0A521 and 0A918:
0A606-  Ground vehicles and related commodities, as follows (see List of Items Controlled): License Requirements;
- 0A617 – Miscellaneous ‘‘equipment,’’ materials, and related commodities (see List of Items Controlled).
3. (ECCN) 0A918 – Miscellaneous Military Equipment Not on the Wassenaar Munitions List (see List of Items Controlled)  is amended by:
- changing the License Exceptions section;
- changing the List of Items Controlled section
4. Addition of  ECCNs  0B606 and 0B617 between ECCNs 0B521 and 0B986:
0B606 – Test, inspection, and production ‘‘equipment’’ and related commodities, not enumerated on the USML, ‘‘specially designed’’  for  the ‘‘development,’’ ‘‘production’’ repair, overhaul, or refurbishing of commodities enumerated in ECCN 0A606 or USML Category VII (see List of Items Controlled).
0B617-  Test, inspection, and production ‘‘equipment’’ and related commodities ‘‘specially designed’’ for the ‘‘development,’’ ‘‘production,’’ repair, overhaul, or refurbishing of commodities enumerated in ECCN 0A617 or USML Category XIII, and ‘‘parts,’’ ‘‘components,’’ ‘‘accessories,’’ and ‘‘attachments’’ ‘‘specially designed’’ therefor (see List of Items Controlled).
5. Addition of  ECCNs 0C606 and 0C617 after ECCN 0C521:
0C606 -  Materials ‘‘specially designed’’ for  commodities controlled by ECCN 0A606 not elsewhere specified in the USML (see List of Items Controlled).
0C617 -  Miscellaneous Materials ‘‘Specially Designed’’ for Military Use (see List of Items Controlled).
6. Addition of new ECCNs 0D606 and 0D617 after 0D521:
0D606 ‘‘Software’’ ‘‘specially designed’’ for the ‘‘development,’’ ‘‘production,’’ operation, or maintenance of ground vehicles and related commodities controlled by 0A606, 0B606, or 0C606 (see List of Items Controlled).
- 0D617 ‘‘Software’’ ‘‘specially designed’’ for the ‘‘development,’’ ‘‘production,’’ operation, or maintenance of commodities controlled by 0A617, ‘‘equipment’’ controlled by 0B617, or materials controlled by 0C617 (see List of Items Controlled).
7.  ECCN 0E018 – ‘‘Technology’’ for the ‘‘development,’’ ‘‘production,’’ or ‘‘use’’ of items controlled by 0A018  is amended by adding a note at the end of the entry
8.  Addition of new ECCNs 0E606 and 0E617 between ECCNs 0E521 and 0E918:
0E606 -  ‘‘Technology’’ ‘‘required’’ for the ‘‘development,’’ ‘‘production,’’ operation, installation, maintenance, repair, overhaul, or refurbishing of ground vehicles and related commodities in 0A606, 0B606, 0C606, or software in 0D606 (see List of Items Controlled).
0E617  – ‘‘Technology’’ ‘‘required’’ for the ‘‘development,’’ ‘‘production,’’ operation, installation, maintenance, repair, overhaul, or refurbishing of commodities controlled by ECCN 0A617, ‘‘equipment controlled by 0B617, or materials controlled by 0C617, or ‘‘software’’ controlled by ECCN 0D617 (see List of Items Controlled).

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 denied party screening, product export classification, 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.

1 comment:

  1. I have attached a document that states the Category 7 item have been move from the munitions list to the commerce list.

    It is No longer considered to be under the jurisdiction of the USML (United State Munitions List) of the Department of State and moved to CCL – the Department of Commerce. Furthermore, the revision identifies new ECCN’s of “600 series” created by movement of certain items within the Commerce Control List..

    Our products have been kicked off the Munitions List to the Commerce list hence the new classification ECCN Code is 0A606 which now does not require us to get an export license We can ship good to all authorized countries except countries that have trade embargo i.e North Korea, Iran, ETC


    Ken


    ReplyDelete