As described in our April 25, 2013 International Trade &
Compliance Advisory, the U.S. government is engaged in a broad
export control reform initiative. On October 15, 2013, the
first regulatory amendments implementing export control reforms
will take effect. These amendments will modify the U.S. State
Department's International Traffic in Arms Regulations
("ITAR"), which generally apply to military items, and
the U.S. Commerce Department's Export Administration
Regulations ("EAR"), which generally apply to commercial
"dual use" items. The amendments will transfer many types
of equipment and software from the ITAR to the EAR.
These first ITAR and EAR amendments address aircraft, certain
aircraft engines and related items. Other amendments covering other
types of items have been and will be proposed and are scheduled to
come into effect in the months following October 15. As the new
export control rules begin to take effect, U.S. and non-U.S.
companies should be