DDTC Updates Guidance on Requests for DSP License Proviso Reconsideration/Clarification
The Directorate of Defense Trade Controls has updated its guidance “Requests for Proviso Reconsideration and/or Clarification” to include additional instructions for replacement DSP authorizations.
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
(A license holder may request reconsideration and/or clarification of a proviso imposed on a DDTC authorization. For DSP licenses, a request for reconsideration and/or clarification of a proviso can be submitted as: (1) a General Correspondence request or (2) a replacement DSP authorization.)
Replacement Requests Must Now Restate Original Purpose
The guidance continues to state that for requests via replacement DSP authorizations, in the purpose block, the applicant should identify the submission as a “Proviso Reconsideration of [license number]”. There must be no other changes to the license application and this must be stated in the purpose block.
DDTC updates the guidance to add that the applicant must also restate the original purpose description as this is a replacement authorization.
Original Support Documentation Must Also be Included in These Requests
The updated guidance also states that the application for requests via replacement DSP authorizations must include the original support documentation. (The original guidance stated that there is no need for a resubmission of the original support documentation.)
DDTC notes that the procedures for proviso reconsideration and/or clarification for agreements are covered in the “Guidelines for Preparing Agreements.” (See ITT’s Online Archives or 04/29/10 news, 10042917, for BP summary of DDTC’s most recent revision of these Guidelines (Revision 2).
(See ITT’s Online Archives or 06/03/10 news, 10060320, for BP summary of DDTC’s original guidance.)