Export Control Reform Update

Exporting firearms is a complicated process.   Small arms and ammunition products were regulated under the State Department for decades.  Export Control Reform (ECR) was an initiative that started in 2009 to update and streamline U.S. export regulations.  On January 23, 2020, the final rules were posted for public review and the regulations took effect on March 9th (https://www.govinfo.gov/content/pkg/FR-2020-01-23/pdf/2020-00573.pdf) that transitioned certain United States Munitions List (USML) Category I (Firearms), Category II (Armament) and Category III (Ammunition) from the State Department’s oversight to the Commerce Department.

Under the transition there were new Export Control Classification Numbers (ECCN’s) created to accommodate the items that moved from the USML to the Commerce Control List (CCL).  There has been some confusion as to what Automated Export System (AES) code exporters were supposed to use for the newly created ECCN 0A501.y items when filling out their Electronic Export Information (EEI).

On June 15th, a new AES license type C63 (YFA) was added specifically to capture 0A501.y commodities.  Orchid Advisors has been following the development and implementation of the new regulations.  If you have questions about how the new firearm export regulations could impact your firearms business, please contact us.  We are here to help.

About Orchid Advisors

Orchid Advisors provides technology and services to the shooting sports industry. The company offers business and compliance software accompanied by expert consulting services which improve how products are imported, manufactured, distributed and sold to consumers both in-store and online. The firm offers regulatory business training, FFL and import / export licensing and software solutions which aid in the commerce of firearms. For additional information, visit www.OrchidAdvisors.com.