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February 9, 2017

Joiner Trade Solutions – Client Alert

In December 2016, BIS revised the Commerce Control List (CCL) to implement certain decisions, recommendations, and/or understandings reached by two multilateral export control regimes -- the Australia Group and the Nuclear Suppliers Group.  Below is a brief synopsis of the changes. 

BIS Amends EAR to Implement 2016 Decisions, Understandings Reached by Australia Group

On December 16, 2016, BIS amended the EAR to implement the recommendations and understandings reached by the Australia Group in February and June of 2016.  The final rule amended ECCN 1C351, which controls certain human and zoonotic pathogens and toxins, and ECCN 2B352, which controls equipment capable of use in handling biological materials.  As a result of the final rule, the dengue fever virus (formerly controlled under 1C351) is now designated as EAR99 and no longer requires a license for CB or AT reasons.  Moreover, the final rule, among other things, expanded the controls (in 2B352.a) on biological containment facilities and related equipment. 

BIS Revises Nuclear Non-proliferation Controls on Certain Items

On December 27, 2016, BIS amended the EAR to reflect certain understandings reached by the Nuclear Suppliers Group in 2015 and 2016.  The amendment addressed the nuclear nonproliferation (NP) controls that apply to certain centrifugal multiplane balancing machines (ECCN 2B229) and linear displacement measuring systems (ECCN 2B206) identified on the CCL.  The amendment also made additional changes to the description of these systems on the CCL and corrected an error in the technical parameters of the CCL entry that describes certain radiation-hardened TV cameras (including lenses therefor) (ECCN 6A203). 

It is important for organizations to regularly update their trade compliance programs to incorporate, among other things, changes to U.S. government regulations that relate to international trade compliance.  Joiner Trade Solutions®, a service offering of Joiner Law Firm PLLC, monitors changes to U.S. trade regulations and is prepared to assist your organization with updates to its trade compliance programs.