Transfer of Control for Certain War Vessels to CCL

Resulting from the recent export control reform perhaps one of the most extensive update was moving several USML controlled Surface vessels of war, Submersible vessels, Oceanographic Equipment as well as Related items, Auxiliary vessels and Miscellaneous items and associated accessories, parts, and commodities to EAR Commerce Control List. Even though the BIS and DDTC agencies are going to do and actually start to share more detailed analysis of the final rule, at first glance I noticed the below listed changes in Cat 8 and Cat 9 of the EAR CCL. Note that the final rule will go into an effect on January 6, 2014, and it is crucial for the companies and organizations to be prepared for the changes by perhaps revisiting and revising their both EAR and ITAR compliance programs: - 8A018 - Items on the Wassenaar Arrangement Munitions List is changed. - Inclusion of new ECCNs 8A609 and 8A620 between ECCNs 8A018 and 8A918: - 8A609 - Surface vessels of war and related commodities. - 8A620 - Submersible vessels, oceanographic and associated commodities. - New ECCNs 8B609 and 8B620 are added immediately after ECCN 8B001: - 8B609 - Inspection, testing and production Equipment and related commodities for the commodities enumerated in ECCN 8A609 or USML Category VI (except for Cat VI(f)(7)). - 8B620 - Inspection, testing and production Equipment and related commodities of commodities enumerated in ECCN 8A620. - Inclusion of a new ECCN 8C609 - Materials for the items controlled by 8A609 not elsewhere specified in the USML, directly following ECCN 8C001. - Addition of new ECCNs 8D609 and 8D620 between ECCN 8D002 and 8D992: - 8D609 - Software for items commodities controlled by 8A609, 8B609, or 8C609. - 8D620 - 'Software for commodities controlled by 8A620 or 8B620. - Inclusion of new ECCNs 8E609 and 8E620 between ECCN 8E002 and 8E992: - 8E609 - Technology for the items controlled by 8A609, 8B609, or 8C609, or software controlled by 8D609. - 8E620 - Technology related to commodities controlled by 8A620 or 8B620, or software controlled by 8D620. - 9A018 - Equipment on the Wassenaar Arrangement Munitions List is modified. - 9A619 - Military gas turbine engines and related commodities, the Note at the end of paragraph.a in the Items paragraph of the List of Items Controlled section is changed. - 9D018 - Software for the use of equipment controlled by 9A018 is changed. - 9E018 - Technology for the equipment controlled by 9A018 is modified.


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, export classification, eccn, 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.