Export Control Reform (ECR) Transition Date: Monday, November 10, 2014
Under the Export Control Reform (ECR) Initiative to transition selected items from State to Commerce department jurisdiction, the second phase of the USML Category XV, spacecraft systems and related equipment, goes into effect this coming Monday, November 10, 2014.
Export Control Reform reclassification can be complex and tedious but to the departments of State and Commerce the revised classification must be accurate.
Customers in the industries of Aerospace / Satellite manufacturing will be affected most immediately. We believe such customers should consider the following actions:
- Submit the open declaration, if any, prior to November 10, 2014.
- NEW ECCNS – If there’s no data provider then manually create new ECCN or contact data provider to send updated XML file.
- Reclassify the materials (Spacecraft/Satellites parts) to the new ECCN 9×515.
- Some items will require license to export to D:5 Country groups, so obtain the license and maintain in the GTS system. Also to check with AES to see if there’s any specific Customs code for the licenses. The License exception may apply for certain items exported to certain countries. It is possible existing License exceptions (LVS, TMP, RPL, GOV, TSU, STA) can be used.
- Define new License determination strategy.
- If there are any open orders or deliveries that are not yet shipped after November 10, 2014 then re-determine the ECCN and Licenses for these transactions.
- If there are any re-export considerations then configuration changes for the new ECCNs to apply de-minimis rules.
Please note, each company will have different requirements and exceptions. The above are a general set of considerations and guidelines. If you are unsure, Krypt can help you with determining your next steps. For help or questions contact us at info@kryptinc.com
