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In coordinated announcements last week, BIS and DDTC proposed many new or altered definitions that attempt to harmonize comparable terms in the EAR and ITAR. The DDTC proposal includes, among many others, a new definition of “defense services.”
Want the Commerce Control List (CCL) made clear? Need faster, easier classifications? You’re in the right place.
When classifying items under the Export Administration Regulations (EAR), the phrase “Parts and Components” consistently appears in the various Export Control Classification Number (ECCN) entries on the Commerce Control List (CCL).
We often get this question from prospective clients, even before we know anything about the items on their list. This is like taking your car to a mechanic and asking, “How much to fix my car?” Since he doesn’t yet know what’s wrong, the mechanic can’t know how long it will take to fix.
On August 17, 2016, the Bureau of Industry and Security and the Department of State published final rules (here and here) to harmonize the Destination Control Statement (DCS) required under §758.6 of the Export Administration Regulations (EAR) and §123.9 under the International Traffic in Arms Regulations (ITAR) respectively.
Commodity classification is critical. In fact, we call it Job #1 since most of your compliance requirements are based on these determinations. But classification projects are not all the same.
You’ve worked out your classification strategy and your budget. Now it’s time to prepare. What does that entail? What information is required to conduct a comprehensive, efficient and accurate export classification project?
President Obama and the administration are moving full steam ahead to normalize bilateral relations with Cuba.
The folks at DDTC are beginning a slow roll out of their new electronic interface, DECCS, starting next week. DECCS, which stands for the Defense Export Control and Compliance System, is DDTC’s new modernized IT system.
With H-1B visa window approaching, there is renewed attention on the I-129 visa application, notably the certification that “[a] license is not required from either the U.S. Department of Commerce or the U.S. Department of State to release such technology or technical data to the foreign person.”
DTrade DSP forms and forms viewer have been upgraded to support SHA-256 digital certificates as required by federal mandate. Effective November 25, 2013 the use of the new forms (v8.0) will be mandatory and users may begin using SHA-256 digital certificates to access DTrade, as well as digitally sign and submit the DSP forms listed above.
On June 20, 2013 U.S. Department of Commerce published revisions to the Export Administration Regulations based on the most recent agreements in Wassenaar. These EAR changes to the Commerce Control List (CCL) in Category 7 implementing the Wassenaar agreement significantly reduced the level of technology control for Fly-by-Wire technology in ECCN 7E004b.
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