The Directorate of Defense Trade Controls (“DDTC”) and the Bureau of Industry and Security (“BIS”) have proposed changes to U.S. Munitions List (“USML”) Category XII and the Commerce Control List (“CCL”). In sum, the proposed rule seeks to create a “bright line” between the USML and the CCL for the control of the articles found in Category XII and makes a number of alterations to the CCL. The proposed rule also seeks to alter the CCL by creating new 600 series Export Control Classification Numbers (“ECCNs”) for certain items and creating or revising other ECCNs. Affected products include military fire control, range finder, optical items, guidance system, certain night vision items, certain software and technology related to night vision items, and certain cameras, systems or other equipment.
Industry comments on the proposal are due July 6, 2015. Should you have any further questions or need assistance with the comment process, please contact our firm at (713) 932-1540. You can also read the DDTC proposal here and the BIS proposal here.