Export Control Reform—The Challenges
If your company deals with any goods that are currently listed on the United States Munitions List (USML), swiftly oncoming Export Control Reform changes are very likely to affect you and your export compliance workflow procedure.
Visual Compliance Export Control Reform solutions can help to simplify the process of reclassifying your goods based on Export Control Reform changes to the USML and the CCL. Contact us to request a demo.
Export Control Reform Reclassifications from USML to CCL
Even if your organization's goods turn out not to be among those items that are changing status due to export control reform, it's vital that you know whether or not your process needs to evolve to become compliant with a different regulatory regime.
The essence of the Export Control Reform initiative is that, by streamlining the export control process, unifying disparate certification bodies, and easing constraints for certain items that have been identified as excessively restricted up to this point, the U.S. government seeks to promote more robust international trade—particularly with the European Union (E.U.)—while also making it simpler to enforce the constraints on exporting military and aerospace goods to help keep controlled technology out of the hands of terrorist groups and other unauthorized foreign nationals.
However, the task of staying up-to-date with all the export control reforms and the ongoing reclassifications of goods they entail presents a distinct challenge—particularly in the case of manual-only export compliance processes.
USML to CCL Export Control Reform changes and what they mean for your company
Many items will be moving from the United States Munitions List to the Commerce Control List (CCL), transferring jurisdiction from the Department of State to the Bureau of Industry and Security. This means that any goods your company currently produces or exports that, until now, have been regulated by the United States Munitions List may, in the future, be regulated instead by the Commerce Control List, and consequently, the classification numbers for those items will also be changing. For organizations dealing with large quantities of different goods, you could be looking at potentially hundreds of modifications to the classification numbers for your goods.
The USML to CCL changes are mandatory.
Reclassifying your goods to conform to the new Export Control Reform identification standards is not optional. When the final approvals for transferring items from the United States Munitions List to the Commerce Control List are complete, items for export that are classified under the old classification system will be considered incorrectly classified, and will not be permitted to be exported. If you fail to keep pace with the updated classification numbers, you may find that hundreds of your products are suddenly misclassified, your export licenses denied, and your products stranded at the border indefinitely. The damage to your business and its reputation if your exports are halted due to incorrect classification numbers would be potentially irreparable.
Trawling through the lists to identify all your United States Munitions List products that will be moving over to the Commerce Control List under the Export Control Reform initiative would be a labor-intensive and time-consuming venture if it has to be done manually; and keeping up with ongoing export control reforms, to lists as well as to regulatory bodies and jurisdictions, is likewise a daunting prospect. Contact us today to find out how we can help you meet the challenges of Export Control Reform.