2 Regulations…1 Destination Control Statement

2015/07/14

By: Danielle McClellan

On May 22, 2015 the Directorate of Defense Trade Controls and the Bureau of Industry and Security proposed rules that would change the EAR destination control statement to read the same as the ITAR destination control statement. Many exporters have shipments that contain both EAR and ITAR goods which creates issues when deciding which statement should be included…or if both statements should be included. The goal of this proposed  rule is to make exporter’s lives a bit easier…something we don’t see very often—but then again this is only a proposed rule.

To a certain extent, BIS already fixed the dual DCS problem for shipments containing both EAR and ITAR items.  BIS previously revised 758.6(a) of the EAR to state that using the ITAR DCS constitutes compliance with the EAR DCS requirement for shipments containing both EAR and ITAR items.  The proposed rules, if implemented, would go beyond this BIS quick fix for mixed shipments to a single DCS for all exports.

The Department of State Federal Register notice can be accessed online here.

The BIS Federal Register notice can be accessed online here.

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