Export Controls Reform - Category VIII Transfer

On November 7, 2011, the US Department of Commerce, Bureau of Industry and Security ("BIS") and the US Department of State, Directorate of Defense Trade Controls ("DDTC") published parallel proposed rules aimed at transferring current United States Munitions List ("USML") Category VIII articles to a new Commerce Control List ("CCL") classification. The proposed rules, at 76 Fed. Reg. 68675 and 76 Fed. Reg. 68694, are part of the Administration's ongoing Export Control Reform Initiative, and are the second of a planned series aimed at transferring articles from the USML to the CCL.  The first proposed transfer of USML items to the CCL covered Category VII (military vehicles and related articles), and was published in a July 15, 2011 proposed rule (see our August 5, 2011 update). Both BIS and DDTC are accepting comments on the November 7^th proposed rules until December 22, 2011.