Proposed Rule Narrows ITAR Coverage of Personal Protective Equipment

This post was written by Michael J. Lowell.

The Directorate of Defense Trade Controls (“DDTC”) is currently accepting comments to a proposed revision to Category X of the U.S. Munitions List (“USML”) in the International Traffic in Arms Regulations (“ITAR”), which covers personal protective equipment, including body armor. The proposed rule was published June 7, 2012, in coordination with a proposed revision to the Commerce Control List of the Export Administration Regulations (“EAR’). The proposed changes will further implement the Administration’s Export Control Reform effort and seek to provide additional clarity to exporters while generally decreasing controls on many parts and components, and moving the standard cut-off for ITAR body armor from NIJ Type 3A to NIJ Type 4.

For a more detailed analysis, please click here to read the issued Client Alert.