Articles in Category: Aerospace

Export Control Reform Category VII: Changes affecting the Aircraft and Aviation industry

on Monday, 06 January 2014. Posted in Export Control Reform, ITAR, Aerospace

Suppliers and distributors to the aerospace/defense industry should be aware that the government has made significant changes to the export control regulations affecting the aviation industry. Failure to implement the new regulations can lead to fines and the potential loss of exporting privileges.


At the center of the Export Control Reform Initiative, ECRI, is the movement of many aircraft parts that do not support either military fighter or bomber aircraft from Category VIII on the United States Munitions List to the new 600 series, in this case 9A610, Export Control Classification Numbers on the Commerce Control List. For many companies, this will drastically affect what types of export licenses will be used, or whether the company qualifies for a  license exception in lieu of an export license. The ECRI  specifies that aerospace/defense companies review their United States Munitions List/Commerce Control List product classifications and re-classify their products to comply with the new laws. 


The MK Trade Compliance Group can provide your company and your employees with export compliance awareness training and product line classification review so that they can remain up to date with these regulatory changes, determining which products stay on the State Department's US Munitions List and which transition over to the Commerce Control List. We can assist you in the re-classification of your product lines and the sorting of your parts and components data base so that your company is in full compliance with the new Commerce and State Department regulations.


As pointed out by Assistant Secretary of Commerce for Export Administration, Kevin Wolf, "once you have endured the short-term pain of reviewing your compliance program, you should be able to reap the long-term benefits of a simpler system requiring fewer validated licenses." In many cases, your company may qualify for the use of license exception STA (Strategic Trade Authorization) instead of applying for a Commerce license. The results can be favorable but it requires a re-classification process.   


Let us help you minimize the pain and maximize the benefits. See the links below to our site and to some yardsticks you can use to measure your compliance program. Have questions or need assistance? Give us a call or email and we'll 

be happy to help.

AEROSPACE -- -- Dealing with Regulatory Complexity

on Monday, 27 May 2013. Posted in Aerospace

Aerospace companies have been under particular regulatory uncertainty and pressure in the past few years.


Historically, Aerospace companies have experienced regulatory uncertainty and licensing delays stemminfrom an overly complex export control system. A number of companies have also faced demands for "ITAR-free" products where U.S. made parts and components are designed out in the design plan. 

Small and Medium-sized Enterprises, SMEs were often the victim of this effort to avoid the reach of U.S. munitions controls, but the ongoing Export Control Reform initiative should make them the beneficiaries of the decontrol or the transfer of thousands of parts and components frothe State Department's Munitions List to the Commerce Department's Commerce Control List.  SMEs frequently don't have fully developed compliance programs, including the in-house compliance expertise of the larger companies and as a result they have sometimes held bacfrom aggressively pursuing export opportunities.

At MK TCG we have experienced consultants who can help your company make the transition ta new regulatory framework with the background and expertise required to train your the internal compliance program, classify your products. and make commodity jurisdiction and CCATS requests. Whether you are a supplier to or a sub of  one of the defense primes or an Unmanned Air Systems provider. we can assist your company in complying with the latest provisions of the regulatory changes.

Did you know that parts that are not "Specially Designed" but rather common to military and civilian aircraft and not found on the USML would be subject to the Export Administration Regulations? Did you know that parts and componcnts  may be exported or reexported in License Exception STA (Strategic Trade Authorization), but certain software and technology related to their "Development"' or "Production" may not be?

ITAR Categories VIII (military aircraft) and XIX (turbine engines) have already had regulations published with dramatic changes announced that would shift many items from State Department to Commerce Department control. Aerospace companies, among others, face penalties ranginfrom warnings and small fines to actual denial of export privileges and/or the prohibition against selling to the U.S. Government and they will face increasing pressure to 'put more significant resources into the effort to stay current with the new rules and regulations.