DDTC Requests Comment on ECR Guidelines
The State Department’s Directorate of Defense Trade Controls (DDTC) requested comment for DDTC guidelines designed to help exporter applicants implement requirements of the various Federal Register notices that pertain to Export Control Reform (ECR). The first set of ECR rules will take effect Oct. 15 (see 13091913). DDTC also released the guidelines (here) Sept. 23. Interested parties should comment via DDTCResponseTeam@state.gov.
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In addition to moving some U.S. Munitions List commodities to the Commerce Control List (CCL), ECR is adding a (x) subcategory which allows, in certain circumstances, exporters to obtain a DDTC for the export of CCL-controlled commodities, software and technical data. The guidelines include a table that provides timeline guidance for submitting specific agreements, amendments and IFO licenses. The table includes the following applicable time periods:
- Prior to effective date of relevant final rule
- On effective date of relevant final rule
- Two years after effective date of relevant final rule