On Monday, March 9, 2020, as scheduled, the Export Control Reform rules for United States Munitions List (USML) Categories I, II, and III (firearms, artillery, and ammunition) took effect.
As described in our earlier blog post and the Federal Register Notices, items that the U.S. government has determined not to provide the U.S. with critical military or intelligence advantages or perform an inherently military function have been transferred to the Department of Commerce and will be subject to the Export Administration Regulations (EAR).
This concludes the initial review of the United States Munitions List (USML) that started in 2011.
3D Printer Data Excluded
Due to a court-ordered preliminary injunction issued Friday, March 6th as a part of ongoing litigation, “technical data and software directly related to the production of firearm or firearm parts using a 3D-printer or similar equipment” remain subject to the International Traffic in Arms Regulations (ITAR). The injunction did not block the rest of the rule from taking effect.
The Department of State, Directorate of Defense Trade Controls (DDTC) has published a statement on the court order and may publish additional guidance. Please refer to the DDTC website for additional information.