In January 2020, the U.S. State and Commerce Departments published final rules to amend Categories I, II and III of the U.S. Munitions List (USML) in the International Traffic in Arms Regulations (ITAR), effectively transferring certain defense items – firearms, ammunition, components, accessories, production and manufacturing items, and related categories and types of information – from jurisdictional control under ITAR to commodities under the Export Administration Regulations (EAR).

Later implemented March 9, 2020, licenses for items transitioning to the Commerce Control List (CCL) that were issued prior to the effective date of the final rule for each revised USML category, and that did not include any items that would remain on the USML, remained valid until expired, were returned by the license holder, or for a period of three years from the effective date of the final rule, whichever occured first. Now, nearly three years later, those ITAR export authorizations must be transitioned to EAR export authorizations by March 9, 2023.

If your firearms business requires BIS/EAR export authorizations or government-issued licenses, such applications should be submitted no later than the end of January 2023 as the processing of authorizations is expected to take 4-8 weeks. ITAR requirements must also be closed out in associated with this export authorization transition.

To learn more about the ITAR-to-EAR export authorization transition, including items and businesses affected, register for our on-demand export webinar with Orchid’s Director of Export Services, Jason Knowles, and contact us to help you navigate the transition with the utmost compliance.