DDTC - CJ process changes for certain USML categories 

November 14: The U.S. State Department’s Directorate of Defense Trade Controls (DDTC) today announced a new review process for certain U.S. Munitions List items:

According to the DDTC release [PDF 174 KB], newly submitted commodity jurisdiction (CJ) requests that involve articles or services relating to the following four categories of U.S. Munitions List will be reviewed pursuant to changes made to these categories in July 2013:

  • Category VI (Surface Vessels of War and Special Naval Equipment)
  • Category VII (Ground Vehicles)
  • Category XIII (Materials and Miscellaneous Articles)
  • Category XX (Submersible Vessels and Related Articles)

The DDTC stated that the change to the CJ review process is required because of current processing times for CJs (approximately 60 days), because the final determinations for CJs submitted after November 14, 2013, will not be issued until after the effective date (January 6, 2014) for the July 2013 rule.

Today’s change does not affect CJ requests that have already been submitted and are under review.

The DDTC release also states:

  • Exporters and manufacturers are advised to continue using the current control criteria on the U.S. Munitions List until the new control criteria take effect on January 6, 2014.
  • Exporters and manufacturers are further notified that the State Department will implement similar policies for CJ requests for other USML Categories under revision pursuant to Export Control Reform 60 days prior to their effective dates.
  • Today’s notice does not relieve any exporter or manufacturer of its obligations to comply with any licensing and compliance requirements.

For more information, contact a professional with KPMG’s Trade & Customs practice:

Douglas Zuvich

(312) 665-1022

Andrew Siciliano

(631) 425-6057

John L. McLoughlin

(267) 256-2614

Todd R. Smith

(949) 885-5617

Luis A. Abad

(212) 954-3094

Amie Ahanchian

(202) 533-3247

Or your local KPMG Trade & Customs professional.

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