News & Noteworthy

Bruce Webb

Recent Posts

I, II, III . . . . GO! The Beginning is the End of ECR

Posted by Bruce Webb on Jan 22, 2020 10:08:56 AM

It is fitting that the first should be last. The long-awaited revisions of USML Categories I, II, and III are now imminent and will bring the Export Control Reform (ECR) initiative, which began under the Obama Administration, very close to completion.

As compliance experts will remember, the ECR initiative began in 2010 to streamline the USML by tightening its definitions and relaxing controls on less-lethal items. The plan was to transfer select items to the CCL where the manufacturers would benefit from less onerous regulations, but the government would still retain significant, but nuanced, controls to ensure that export policy objectives were attained. The objectives were seen as win-win-win: that is: 1) a  USML list of fewer items and reduced licensing burden for DDTC, 2) lower costs and more nuanced licensing requirements for exporters, and 3) retention of  controls for items transferred  to the EAR with identified targeted purposes, notably national security, nonproliferation, anti-terrorism, human rights or other foreign policy purposes.

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Topics: Export Compliance, USML, Firearms

Export Control 101: Commodity Jurisdiction

Posted by Bruce Webb on Apr 16, 2019 10:15:00 AM

As technical specialists, we often get asked about Commodity Jurisdiction. The questions are simple but important and the answers are invaluable for newcomers to export control.

What is a Commodity Jurisdiction (CJ) determination? The first and most basic step in export control is determining if your item (be it a physical product, software, technology, or service) requires an export license. To ascertain this, you must first verify which set of regulations pertain to that item. It may be the International Traffic in Arms Regulations (ITAR) or it may be the Export Administration Regulations (EAR).  Since the ITAR is administered by the State Department and the EAR is overseen by the Department of Commerce, you are trying to determine which jurisdiction your product belongs to, based on its technical characteristics or capabilities.

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Topics: Export Compliance, Commodity Classification

Using National Stock Numbers for Commodity Classification

Posted by Bruce Webb on Jun 19, 2018 11:25:00 AM

Compliance practitioners know that commodity classifications are the essential first step in determining export control requirements, responsibilities and risks. However, in situations where the exporter is not the original manufacturer of an item or specific product specifications are unavailable, making an export classification determination can be difficult. One valuable and often overlooked piece of information is the National Stock Number (NSN) but it must be used with caution.

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Topics: Export Compliance, Commodity Classification

"Capable of" Confusion

Posted by Bruce Webb on Feb 22, 2018 12:26:10 PM

 

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Topics: Export Compliance, Commodity Classification, Export Control

Paris Air Show: Recap & Highlights

Posted by Bruce Webb on Jul 5, 2017 11:01:00 AM

The Paris Air Show is the largest and most famous Air and Space Exposition worldwide and the 2017 version at Le Bourget airport did not disappoint the huge crowds that braved the blistering heat. From a historical perspective, it was the 90th anniversary of Lindbergh’s 33 hour solo flight from New York to Paris, a route that commercial passenger jets routinely fly now in 7 hours. In these 90 years, aviation technology has advanced at near lightning speed and the Paris Air Show is the world showcase of aviation technology, a stage for a myriad of companies—from the huge aerospace conglomerates to the small, innovative startups—to display their latest innovations. Every other year, Boeing, Airbus, GE, Honeywell and dozens of other U.S. companies and foreign competitors introduce their newest technologies here. Among the 2017 highlights:

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Topics: Export, Paris Air Show