Coming Soon…Definitive Definitions

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.” For the legion of long suffering compliance practitioners who have struggled to reconcile the varying terminology, this is a long awaited aspect of ECR. The proposed rules can be found at:

• BIS: 80 Fed. Reg. 31505
• DDTC: 80 Fed. Reg. 31525

To assist exporters, DDTC has compiled a 25-page chart that compares the proposed definitions. This helpful document is posted on the DDTC website:

http://www.pmddtc.state.gov/FR/2015/Definitions%20Rule%20Harmonization%20Chart.pdf

In addition, BIS is holding a free teleconference to explain and discuss the proposed revisions. On June 10 at 2:30 p.m. Eastern Time, Assistant Secretary for Export Administration Kevin Wolf will hold a 90-minute ECR teleconference to provide an overview of the Commerce proposed rule, Revisions to Definitions in the Export Administration Regulations. He will be joined by a State Department official from the Directorate of Defense Trade Controls. To hear the teleconference, call 1-888-455-8218 and use passcode 6514196. If you are calling in from overseas, the number is 1-212-547-0330.

This chart, and the accompanying teleconference, will be invaluable for compliance practitioners as we all navigate this next phase of ECR.