BIS Plans to "Streamline" TMP License Exception Reg, Reminds Exporters of Evening Counseling, Etc.
The Bureau of Industry and Security completed the first day of its Complying with U.S. Export Controls conference in Washington, DC on May 7. At the two-day conference, which is offered by BIS in several cities throughout the year, BIS and Census outreach and counseling staff provide an in-depth examination of the Export Administration Regulations (EAR). During the first day, BIS provided training on the classification of items on the Commerce Control List (CCL), license exceptions, and how to submit license applications and commodity classification requests to BIS through the Simplified Network Application Process Redesign (SNAP-R). Highlights follow:
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
BIS currently looking to "streamline" regulation for TMP license exception. Noting the length of the provision for the Temporary Imports, Exports and Reexports (TMP) license exception, and in particular the 9 separate authorizations contained in 15 CFR Part 740.9(a), BIS said that it is currently working to streamline the provisions governing this license exception.
Exporter counseling available until 8pm eastern time. BIS noted that exporters often call for counseling late on Friday when facing a deadline for shipment. BIS reminded exporters that although its main exporter counseling line (202-482-4811) is only available until 5pm eastern time, its offices in Northern and Southern California provide counseling until 8pm eastern time (5pm pacific time) (408-998-8806 and 949-660-0144, respectively).
Updates on ECR initiatives available. Noting the frequent changes to the EAR due to the Administration’s Export Control Reform (ECR) initiative, BIS encouraged exporters to sign up for email alerts on regulatory changes, including new final rules, proposed rule, and additions and modifications to the entity list and denied persons list. Email update signup available here.
Weekly ECR update teleconferences provided by Asst Sec’y. BIS also reminded exporters that Assistant Secretary Wolf is conducting weekly teleconferences on Wednesdays at 2pm eastern time. Exporters may submit their questions on ECR by email to oesdseminar@bis.doc.gov. BIS recommended that comments are submitted by 9am on the day of the teleconference, but said questions not received in time will be discussed at the next teleconference. The call-in number is 1 (888) 455-8218 and the participant code is 6514196. BIS noted that the teleconferences are not a forum for comments, only questions. Comments should be submitted according to the procedures outlined in BIS’ proposed rules.
Exporters should use Consolidated Screening List. BIS reminded exporters to use its Consolidated Screening List, which combines the lists in the EAR pertaining several general prohibitions, i.e., the Entity List, Denied Persons List, Unverified List, with OFAC lists, the Debarred List, etc. The Consolidated Screening List, which was announced in December 2010, is available here.
(See ITT's Online Archives 10121018 for summary of announcement of List.)
New BIS website to replace old site soon. BIS said it is monitoring traffic on its old website (here), and once traffic is sufficiently low it will permanently move to its new website (here), currently in its beta version. According to BIS, the new website allows quicker access to certain key webpages to exporters.
Exporters should notify Regulatory Policy office of formatting issues in EAR. Following the discovery of a formatting error in the print version of the EAR at 15 CFR Part 738 Supplement 1 (dotted lines erroneously included on the Commerce Country Chart), BIS said that any errors in formatting in either the print regulations or the online regulations should be reported to the BIS Office of Regulatory Policy at (202) 482-2440. BIS also said that the print version of 15 CFR, published yearly by the Office of the Federal Register, should be used for training purposes only due to frequent changes to the text and tables contained within. Exporters should instead consult the online version of the EAR, available from either the Government Printing Office here or on the BIS website here.
(BIS said that the version of the EAR on its website is usually updated on the effective date of any changes to the EAR, unless the rule is particularly long and complex, in which case updates should take place one to two days after the effective date.)