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ARTICLE · 25 OCTOBER 2013

Export Control Reform Finally Kicks In

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On October 15, 2013, the first set of final rules implementing the US Government’s Export Control Reform (ECR) Initiative took effect, reshaping the structure of US export controls.

United StatesInternational Law
Edward Krauland
Edward Krauland
Meredith Rathbone
Meredith Rathbone
Jack Hayes
Jack Hayes
Peter Jeydel
Peter Jeydel
Elisabeth Page
Elisabeth Page
Jeanne Cook
Jeanne Cook
Andrew Irwin
Andrew Irwin

I. Introduction

On October 15, 2013, the first set of final rules implementing the US Government's Export Control Reform (ECR) Initiative took effect, reshaping the structure of US export controls. The effective date is based on an approximate 180-day period set forth in final rules published on April 16, 2013 by the Department of Commerce, Bureau of Industry and Security (BIS) and the Department of State, Directorate of Defense Trade Controls (DDTC) (collectively the Agencies), amending the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR), respectively. These parallel rules will move a significant number of items (i.e., commodities, technology, and software) from the US Munitions List (USML), maintained by DDTC, to the Commerce Control List (CCL), maintained by BIS. In order to implement the transition, the rules also create new structures to maintain tight controls over certain USML defense articles moved to the CCL

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