ARTICLE · 10 JUNE 2013

Export Control Reform Continues - The May 24, 2013 Proposed Rule Changes

Pepper Hamilton LLP

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The Proposed Rules introduced by the U.S. Department of Commerce’s Bureau of Industry and Security and the U.S. State Department’s Directorate of Defense Trade Controls, a part of the on-going Export Control Reform initiative, are consistent with the previous changes made as part of the initiative.

United StatesGovernment, Public Sector

Robert Thomas Leahy

Michael Ambinder

The May 24, 2013 Proposed Rules introduced by the U.S. Department of Commerce's Bureau of Industry and Security ("BIS") and the U.S. State Department's Directorate of Defense Trade Controls ("DDTC"), a part of the on-going Export Control Reform ("ECR") initiative, are consistent with the previous changes made as part of the initiative. BIS: http://www.gpo.gov/fdsys/pkg/FR-2013-05-24/pdf/2013-11986.pdf DDTC: http://www.gpo.gov/fdsys/pkg/FR-2013-05-24/pdf/2013-11985.pdf They introduce substantive changes to the rules to reduce unnecessary, outdated, or disproportionate regulation, and clarify the current rules to reduce confusion about their interpretation. The broad objective of ECR is to replace existing catchalls with more targeted standards for those items controlled by the International Traffic in Arms Regulations ("ITAR"), which are listed on the United States Munitions List ("USML"). Many articles are being moved from the more restrictive USML, regulated by

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