Are You Ready for the Change in Export Regulations?

(If not, do you want some help?)

Before the end of 2019, the International Traffic in Arms Regulations (ITAR) will cease to control the export of most firearms, ammunitions, parts, accessories and related technical data and services.

Export licensing for the most of the firearms and ammunition industry will move to the U.S. Commerce Department, which administers the Export Administration Regulations (EAR).

Orchid Advisors can ease the transition with our ITAR-to-EAR Transition Services:

On-site Training Programs

Many people in your organization (senior management, sales, compliance, shipping, among others) should become familiar with the new rules, but it isn’t practical to send all of them to off-site conferences. We can give your team a presentation in your own offices that is tailored to what your company needs to know.

Senior Management Presentation – The Strategic Implications of Export Control Reform Firearms and Ammunition Export Licensing under the Export Administration Regulations ITAR-to-EAR Employee Export Compliance Training
This 60- or 120-minute presentation spotlights the export-control opportunities and risks for your company and ways to reshape your international sales program for the new rules. This 60- or 120-minute nuts-and-bolts program covers classification, license determinations, license exceptions, licensing, license management, record-keeping and voluntary self-disclosures under the EAR. It is designed for the individuals with hands-on responsibility for export licensing and shipping at your company. This 90-minute presentation is intended to replace the ITAR-focused annual employee export compliance training programs that most companies in the industry have used to date. This program anticipates the upcoming change in export regulations while focusing most of its attention on the rules currently in effect.

Export Licensing Solutions

  • Is now the time for your company to outsource export licensing? The EAR are more complicated than the ITAR and there is a steep learning curve. We already know EAR licensing. We can prepare your licenses, save you the aggravation show you how to ship orders faster under the new rules.
  • Benefitting from the more flexible licensing rules of the EAR depends on knowing the export classifications of the products you sell. We can classify your product catalogue for you, so you know which exports will no longer require export licenses.
  • Most ITAR agreements (MLAs, TAAs and WDAs) will need to be replaced by EAR technology licenses within three years after the new export rules take effect. Many will need to be replaced much sooner. Our ITAR agreements team, led by DDTC’s former “agreements officer,” will give you a roadmap and prepare your new EAR technology licenses.
Outsourced Licensing Solutions Product Classification ITAR-to-EAR Agreements Strategy

For each of your exports, Orchid will:

  • Advise you on EAR licensing strategy, including blanket licenses and ability to obtain license prior to purchase order
  • Advise on availability of license exceptions
  • Prepare EAR and ITAR licenses when required
  • Conduct prohibited party screens
  • Manage your open licenses
  • Create shipping documents
  • Keep required records
  • Answer your compliance and commercial questions.

You provide us a list of all your products and we give it back to you with the following information (as applicable) for each item:

  • ITAR Category and subcategory
  • Commerce Control List ECCN
  • EAR99 status
  • Orchid blanket license code
  • Schedule B code
  • HTS code

You give us your open MLAs, TAAs and WDAs and, for each agreement affected by the new regulations, we will create an exit strategy consisting of the following:

  • Executive summary
  • Issues / Alternatives / Recommendations
  • Execution timeline
  • EAR technology licenses to replace agreements (when required)
  • Summary EAR-based technology control plan

Download our CEO’s Guide to Firearms and Ammunition Export Control Reform eBook to learn more about how the new export regulations will affect your company.

Firearm Export Control Reform eBook