For years, the U.S. Defense industry has been hamstrung by cumbersome ITAR export controls. The archaic regulations are often leveraged by foreign defence competitors to keep U.S. technologies from international projects. Look for that to change in the near future; in fact, it may already be in the implementation phase.
As always, the proof is in the pudding and this is something where you’ll want to read the fine print. However, if the proposed changes are adopted, and I have every reason to believe they will be, you will benefit from a more streamlined and clearer process.
The proposed changes are described as the “4 singles ” reforms. These modifications include:
- A single, tiered export control list, instead of 2 major (State’s USML & Commerce’s CCL) and some minor lists, which do not really differentiate. It will feature “higher fences around fewer items,” and allow items to progressively move down the tiered list as technologies become more widespread.
- A single, newly created export licensing agency, instead of 3 or more.
- A single agency to coordinate enforcement instead of several.
- A single unified IT system. It would replace the current mix of newer IT systems (Defense), older systems (Commerce, built-in 1987 and not modified much), and mostly paper-based systems (State Department).
Signaling the forward momentum are the rule changes handed down from the Bureau of Industry and Security, which will allow technologies with no or low military or intelligence sensitivity to move off the U.S. Munitions List to the Commerce Control List. Transition to the CCL will require interagency reviews.
Additionally subassemblies, parts and components not “specially designed” for the military will now be subject to the same export control requirements as their commercial market equivalents.
FOG HORN 