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February 18, 2016

BIS Issues Proposed Rule Revising CCL Entries for Military Aircraft, Gas Turbine Engines

On February 9, 2016, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule to revise the Commerce Control List (CCL) entries for military aircraft and military gas turbine engines (as well as related items). Specifically, BIS is proposing to add clarifying text to the descriptions of military aircraft controlled on the CCL and to expand and clarify the list of items controlled for anti-terrorism reasons only. BIS stated that the proposed rule does not impose any additional license requirements on exporters, but merely reduces the level of control applicable to certain items and clarifies the control status of others.

As part of the Export Control Reform (ECR) initiative, certain military aircraft and gas turbine engines along with related items, were removed from the U.S. Munitions List (USML) and added to the CCL on October 15, 2013. Last year, the U.S. Departments of Commerce, State, and Defense reviewed these regulatory changes to assess their effectiveness and utility. BIS issued the Feb. 9 proposed rule based on the results of that review. Those in the business of exporting commodities controlled under ECCNs 9A610, 9A619, 9C610, and 9C619, in particular, should review the proposed changes and consider submitting comments to BIS.[1]

The State Department simultaneously published its corresponding proposed rule revising Categories VIII (aircraft and related articles) and XIX (gas turbine engines and associated equipment) of the USML to describe more precisely the articles warranting control on the USML.

For specific questions concerning these proposed changes and their implications, please contact us.

[1] Comments must be received by March 25, 2016.