Over the past few years, the Export Control Reform initiative has been implemented in phases, with new updates occurring on a fairly frequent basis. Designed to help lessen restrictions on United States exporters, the reforms created by ECR move items formerly classified under the United States Munitions List (USML) and controlled by ITAR to the Commerce Control List (CCL) controlled by the Bureau of Industry and Science.
At Betatronix, we have seen first-hand both the benefits and drawbacks of ECR. The removal of certain restrictions has allowed us to ship items with No License Required (NLR) or with lessened End Use Statement Requirements, both of which have eased the export process significantly.
However, there is a drawback or two. These are related to the confusion over some of the commodity jurisdictions. We have seen this mainly in the area of military aviation components designed for US designations F-16, F18, F-22, and equivalents, as that is how the relevant section (USML VIII) and interpretations have been categorized. Over time, we believe this confusion will dissipate, leaving only benefits for exporters.
Export Control Reform is not yet complete, as the end goal is to have one list of export controlled products combining both the CCL and the USML
. For now, we have to be content with reviewing the regular updates to the controlled item lists. Based on the published rule changes
taking effect November 2014 we anticipate reduced restrictions on the Spacecraft components for communications satellites that Betatronix designs and mnaufactures to be next – a welcome change that we hope many other organizations will be able benefit from as well. It will be interesting to watch ECR as it continues to grow and improve over time.