Census Outlines AES Changes Mandated by USML-CCL Final Rule
The Census Bureau published a broadcast detailing specific changes to the Automated Export System, mandated in the first final rule on U.S. Munitions List-Commerce Control List moves. The rules were released by the State and Commerce Departments April 16 (see 13041705). The broadcast details the addition of 10 new Export Control Classification Numbers added to the AES ECCN reference table. The numbers are 9A610, 9A619, 9B610, 9B619, 9C610, 9C619, 9D610, 9D619, 9E610 and 9E619. Use the following instructions to determine which 600 series items are eligible for certain license types:
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- C30 (BIS license), C31 (BIS Special Comprehensive License), C40 (TMP), C41 (RPL), C42 (GOV), and C59 (STA): 600 series ECCNs are eligible to the extent permitted under parts 740 and 752 of the Export Administration Regulations
- C32 (NLR with a reason for control other than or in addition to AT): All 600 series ECCNs created under this final rule are eligible if exported to Canada. Some of these items were previously authorized under an International Traffic in Arms Regulations Canadian exemption.
- C35 (LVS): The following ECCNs are eligible: 9A610, 9A619, 9B610, 9B619, 9C610 and 9C619.
- C44 (TSU): The following ECCNs are eligible: 9D610, 9D619, 9E610 and 9E619.
If 600 series ECCNs are reported under any other license type, AES will generate a fatal error back to the filer, the broadcast said. An AES filing is required for exports of items classified under 600 series ECCNs, regardless of the item’s value or its destination -- with the exception, however, of 600 series .y paragraph exports.
New License Type C60 for .y paragraph exports
A new license type (C60) DY6 will be created in AES for the reporting of items that fall under 600 series ECCNs with a paragraph .y. If an AES filer submits electronic export information containing a 600 series ECCN with a paragraph .y, then the filer must do so under C60. Items under the .y paragraphs may be exempt from reporting in AES if their value is $2,500 or less, or they are destined for Canada.
- C60 (DY6) -- Reporting an ECCN is not required, but when reported, only the following 600 series ECCNs are eligible: 9A610, 9A619, 9B619, 9D610, 9D619, 9E610, and 9E619. When C60 is used, the filer must report DY6 in the License Number field.
Items subject to EAR, including 600 series items licensed by State under the International Traffic in Arms Regulations
ITAR’s new section 120.5(b) gives State authority to license an item subject to the EAR on an ITAR license. If this happens, the AES filer must report the ECCN or the EAR99 designation in the ECCN field in AES, even if the license type is S05 (DSP-5). All other fields associated with S05 are required. This includes registration number, significant military equipment indicator, USML category code, Directorate of Defense Trade Controls eligible party certification indicator, DDTC unit of measure and DDTC quantity.
A complete list of all of the AES License Type codes and reporting instructions for these types can be found (here). Questions on these changes should be directed to the Bureau of Industry and Security at ECR_AES@bis.doc.gov or by phone. Email ITTNews@warren-news.com for a copy of this AES broadcast.