CommissionIssues

  • Subscribe to our RSS feed.
  • Twitter
  • StumbleUpon
  • Reddit
  • Facebook
  • Digg

Tuesday, September 3, 2013

DDTC Issues Notices on Commodity Jurisdiction Changes and Guidance to Prevent RWAs

Posted on 2:26 PM by Unknown
The State Department's Directorate of Defense Trade Controls (DDTC) released two Industry Notices in the past week providing important information and guidance to exporters and manufacturers of defense articles.

Commodity Jurisdiction Policy Change

The first industry notice, published on August 30, 2013, states that due to the upcoming changes to the U.S. Munitions List (USML) arising from the export control reform (ECR) process, starting on September 1, 2013 DDTC will review newly submitted commodity jurisdiction (CJ) requests involving articles or services relating to USML Categories VIII (Aircraft and Related Articles) and XIX (Gas Turbine Engines and Associated Equipment) using the new version of the USML contained in the final rule that will take effect on October 15, 2013. 

The reason for this change is that the current CJ processing time is 60 days and thus CJs submitted after September 1, 2013 will not be issued until after the final ECR rule goes into effect.

DDTC's notice also notes that exporters and manufactures should continue using "the current control criteria" on the USML until the new rules go into effect on October 15, 2013.

The notice indicates that DDTC will implement similar 60-day policies for CJ requests submitted for other USML categories that will take in the coming months. For example, starting in November 2013, DDTC will begin processing CJs for USML Categories VI (Vessels of War and Special Naval Equipment), VII (Tanks and Military Vehicles), XIII (Auxiliary Military Equipment) and XX (Submersibles) under the new criteria, since the new USML categories will go into on January 6, 2014.

RWA Guidance

Today DDTC's Office of Licensing issued a notice advising exporters submitting licenses for defense articles of the reasons why cases were returned without action (RWA) last week. These reasons include:
  • Failure to provide a purchase order with the submission
  • Provided letter of intent [instead of] purchase order for Significant Military Equipment
  • Not all Party names and addresses were included in submission
  • Insufficient technical data submitted for technical review
  • Not following Firearms Guidelines regarding suppressors
  • Exporting CCL items on a DSP-5
DDTC noted that:
"All of these RWAs were preventable. Don’t be one of these people. RWAs waste time, ours and yours."
Exporters are reminded to use the checklists on DDTC's websites when submitting license applications and other authorization requests to DDTC.
 ___________________________________ 
 Our law clerk Andrew Azorsky contributed to this report.

Email ThisBlogThis!Share to XShare to FacebookShare to Pinterest
Posted in | No comments
Older Post Home

0 comments:

Post a Comment

Subscribe to: Post Comments (Atom)

Popular Posts

  • Defense Secretary Gates to Outline Export Control Reform Proposals
    Defense Secretary Robert Gates is expected to announce the results of the Obama Administration's proposed export control reform ...
  • U.S.-China High Technology Working Group to Hold Public-Private Sector Dialogue on September 29, 2009
    The Bureau of Industry and Security (BIS) announced today that the next session of the U.S.-China High Technology Working Group (HTWG), whi...
  • OFAC Announces Rare "Finding of Violation" for Failing to File Blocked Property Reports
    OFAC's Office of Enforcement last week issued a rare " Finding of Violation " to Visa International Service Association for fa...
  • DDTC Issues Announcement Regarding Use of USML Category XXI
    The State Department's Directorate of Defense Trade Controls (DDTC) issued an announcement (doc) today that could impact many exporter...
  • ITC Initiates Section 421 Market Disruption Investigation on Tires From China
    The U.S. International Trade Commission (ITC) announced in today's Federal Register the initiation of a market disruption investigation...
  • U.S. Securities and Exchange Commission Issues Answers to FAQs on Iran Reporting Requirements
    The U.S. Securities and Exchange Commission (SEC) yesterday issued some answers to frequently asked questions on the new reporting requireme...
  • Photos From BIS 2010 Export Control Forum
    Below are some photos from the Bureau of Industry and Security's 2010 Export Control Forum that was held earlier this week in Irvine, Ca...
  • ITAR Freight Forwarder Update: Panalpina Removed from EPLS
    As a follow-up to our February 26, 2012 post on the proposed debarment of a number of freight forwarders and the impact on ITAR-related tr...
  • Florida Jury Convicts Defendant for Conspiring to Violate U.S. Export Control Laws
    A federal court jury in Fort Pierce, Florida last week convicted a defendant of seven counts of conspiring to violate U.S. export control la...
  • DDTC Issues Notices on Commodity Jurisdiction Changes and Guidance to Prevent RWAs
    The State Department's Directorate of Defense Trade Controls (DDTC) released two Industry Notices in the past week providing important i...

Categories

  • 10+2 (1)
  • 2B350 (1)
  • AES (12)
  • Antidumping (17)
  • ATPA (1)
  • Belarus (2)
  • best practices (1)
  • BIS (56)
  • BIS Update Conference (14)
  • BIS; EAR (22)
  • BIS; EAR; (7)
  • Boycotts (2)
  • Burma/Myanmar (1)
  • C-TPAT (3)
  • Canada (2)
  • CBP (20)
  • CBP; Marking (1)
  • CEEC (1)
  • Census (11)
  • CFIUS (2)
  • China (8)
  • China; (11)
  • Commerce Department (2)
  • Congress (10)
  • Countervailing Duties (8)
  • CPSC (1)
  • Cuba (18)
  • Customs (12)
  • Customs Brokers (1)
  • DDTC (21)
  • EAA (1)
  • Export Controls (144)
  • Exports (17)
  • FAST (1)
  • FCPA (34)
  • Free Trade Agreements (4)
  • GSP (8)
  • HTS (2)
  • Incoterms (8)
  • India (6)
  • ITAR (46)
  • ITC (2)
  • Japan (2)
  • Libya (5)
  • Miscellaneous (27)
  • NASA (3)
  • North Korea (8)
  • OFAC (36)
  • Sanctions (10)
  • Sanctions; Iran (58)
  • Sanctions; Sanctions; Syria (1)
  • Sanctions; Sudan (6)
  • Sanctions; Syria (6)
  • State Department (4)
  • Trade Policy (1)
  • TSRA (1)
  • Twitter (1)
  • UAE (5)
  • United Kingdom (1)
  • United Nations (3)
  • USTR (3)
  • Vietnam (2)
  • WTO (2)
  • Zimbabwe (1)

Blog Archive

  • ▼  2013 (17)
    • ▼  September (1)
      • DDTC Issues Notices on Commodity Jurisdiction Chan...
    • ►  August (4)
    • ►  July (1)
    • ►  June (1)
    • ►  May (5)
    • ►  April (2)
    • ►  March (2)
    • ►  January (1)
  • ►  2012 (32)
    • ►  December (3)
    • ►  October (5)
    • ►  August (3)
    • ►  July (6)
    • ►  June (1)
    • ►  May (2)
    • ►  April (2)
    • ►  March (5)
    • ►  February (4)
    • ►  January (1)
  • ►  2011 (63)
    • ►  December (7)
    • ►  November (1)
    • ►  October (6)
    • ►  September (7)
    • ►  August (6)
    • ►  July (1)
    • ►  June (2)
    • ►  May (10)
    • ►  April (1)
    • ►  March (6)
    • ►  February (4)
    • ►  January (12)
  • ►  2010 (114)
    • ►  December (12)
    • ►  November (2)
    • ►  October (1)
    • ►  September (6)
    • ►  August (16)
    • ►  July (16)
    • ►  June (9)
    • ►  May (2)
    • ►  April (8)
    • ►  March (11)
    • ►  February (19)
    • ►  January (12)
  • ►  2009 (237)
    • ►  December (35)
    • ►  November (10)
    • ►  October (4)
    • ►  September (29)
    • ►  August (10)
    • ►  July (22)
    • ►  June (13)
    • ►  May (11)
    • ►  April (20)
    • ►  March (24)
    • ►  February (29)
    • ►  January (30)
  • ►  2008 (37)
    • ►  December (37)
Powered by Blogger.