Tag: ecr

Recommendations for the Next Reform

The complexity of U.S. export control regulations is at an all-time high. If you had the ability to decide the next administration’s export control reform agenda, what would it be? PAST REFORMS U.S. export controls are principally administered by the State Department under the International Traffic in Arms Regulations […]

New Definitions of “End-Items” and “Systems” Create More Headaches

Many exporters will struggle to determine commodity jurisdiction under the definition of “specially designed” created by the President’s Export Control Reform Initiative (“ECR”). Unfortunately, exporters must also now contend with another obstacle to self-classification: ECR’s new definitions for “end-items” and “systems” in the International Traffic in Arms Regulations […]

The Truth About the Obama Administration’s Export Control Reform

Over the years, private industry, academia, think tanks, and even the government have come to criticize the U.S. Export Control System as outdated, too complex, and inefficient. Chief among these criticisms where complaints that the regulations are too long, littered with frequent cross-references with requirements for a single transaction […]

The Single IT Platform Blues

Administration officials claim that complex changes being made as part of the President’s Export Control Reform (“ECR”) Initiative are necessary prerequisites to establishing a single export control list and single export licensing agency. ECR promises to support these “singularities” with a single export agency information technology (“IT”) platform. […]

Specially Designed for the Omniscient

Does your company know all the different ways a person anywhere in the world has used your product? If not, it may be among the many companies encountering difficulty with subparagraph (a)(2) of the new “specially designed” definition. Specially Designed Refresher As part of President Obama’s Export Control […]