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.