|Sunday, 09 October 2011 00:00|
For lawyers and other export controls professionals, the State Department's decision this week to finally start publishing its Commodity Jurisdtion (CJ) determinations on the State Department website is long overdue and a very welcome development.
A CJ is used when a company or another entity is unsure whether an item or service is subject to export controls administed by the State Department Directorate of Defense Trade Controls (DDTC). A CJ determination advises you if the item or service is covered by the U.S. Munitions List (USML) and subject to controls pursuant to the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR). It can also lead to a review by the U.S. Department of Commerce Bureau of Industry and Security (BIS) for controls pursuant to the Export Administration Act and the Export Administration Regulations (EAR).
The Obama Administration in the Fall of 2009 set in a motion a broad-based inter-agency review of U.S. export controls that built upon reforms started during the Bush Administration. The Obama Administration decided to launch an Export Control Reform Initiative that aims to update U.S. export control laws and regulations. The publication of CJ outcomes is part of that reform process.
To access prior DDTC CJ determinations, visit the DDTC website.