State Posts Comments on Proposed Revision of USML Category X
The State Department’s Defense Directorate of Trade Controls posted comments it received in response to its proposed rule to amend Category X (personal protective equipment and shelters) of the U.S. Munitions List. Companies and organizations that submitted comments include Boeing, DRS Technologies, IPC, the Proprietary Industry Association, and BAE Systems, plus two anonymous comments. Comments covered the following issues (partial list):
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- Doubtful jurisdiction between the Commerce Control List and the USML
- Omissions of Wassenaar Arrangement controls
- Proposed USML control of goggles, spectacles or visors (which a commenter said would capture many commercial safety goggles)
- A lack of clear treatment for printed boards and their designs
- Control of parts and components (which one commenter suggested should mostly be decontrolled or eligible for a Bureau of Industry and Security express license)
- Difficulty using the International Traffic in Arms Regulations (ITAR) 123.17 exception for export of personal protective equipment in light of Defense Department and CBP requirements
- Control of shelters
(See ITT’s Online Archives 12060705 for summary of State’s proposed revision of USML Category X.)