Transition Planning Under Export Control Reform December 2013 AEROSPACE & DEFENSE 1 Avionics Rotron Mil Aero Air Technology Sensors.

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Presentation transcript:

Transition Planning Under Export Control Reform December 2013 AEROSPACE & DEFENSE 1 Avionics Rotron Mil Aero Air Technology Sensors

COMPANY CONFIDENTIAL Aerospace & Defense Division THERMAL MANAGEMENT SYSTEMSMAINTENANCE REPAIR OVERHAULMEASUREMENT & POWER SYSTEMS Action Plan for Category VIII reforms Re-determine export jurisdiction and classification for your items and implement new determinations –12,500 SKUs with activity over last 5 years –Extremely time consuming “Specially Designed” and new “600 series” ECCN Category VIII vs. new Category XIX Requires documentation Revise policies, procedures, manuals, standard job instructions Train relevant business functions (e.g., engineering, contracts, supply chain/procurement, IT, legal, etc.) –Develop a communication plan to ensure all personnel are aware of changes 2

COMPANY CONFIDENTIAL Aerospace & Defense Division THERMAL MANAGEMENT SYSTEMSMAINTENANCE REPAIR OVERHAULMEASUREMENT & POWER SYSTEMS Backup 3

COMPANY CONFIDENTIAL Aerospace & Defense Division THERMAL MANAGEMENT SYSTEMSMAINTENANCE REPAIR OVERHAULMEASUREMENT & POWER SYSTEMS New Definition of Specially Designed Two-part “catch” and “release” structure –Part (a): catches items that are specially designed –Part (b): releases items from control under enumerated circumstances Same definition in CCL and USML (with slight differences) USML and CCL sections containing the term “specially designed” only apply if any of the elements of part (a) apply and none of the elements of part (b) applies Some “release” provisions require release supporting documentation 4

COMPANY CONFIDENTIAL Aerospace & Defense Division THERMAL MANAGEMENT SYSTEMSMAINTENANCE REPAIR OVERHAULMEASUREMENT & POWER SYSTEMS Category VIII Changes 5

COMPANY CONFIDENTIAL Aerospace & Defense Division THERMAL MANAGEMENT SYSTEMSMAINTENANCE REPAIR OVERHAULMEASUREMENT & POWER SYSTEMS New Definition of Category VIII components Revised USML Category VIII = “positive list” of specific types of parts, components, accessories and attachments that continue to warrant control under ITAR with one exception: – Parts, components, accessories and attachments “specially designed” for U.S.-origin B-1B, B-2, F- 15SE, F/A-18 E/F/G, F-22, and F-35 aircraft and future variants thereof, or the F-117 or U.S. Government technology demonstrators continue to be controlled in “catch all” format [see Category VIII(h)(1) of revised USML] 6

COMPANY CONFIDENTIAL Aerospace & Defense Division THERMAL MANAGEMENT SYSTEMSMAINTENANCE REPAIR OVERHAULMEASUREMENT & POWER SYSTEMS ECCN 9A610 ECCN 9A610.a -.w: Specifically enumerated end items, materials, parts, components, accessories, and attachments –some items may be “specially designed” ECCN 9A610.y: Specifically enumerated parts, components, accessories, and attachments that are “specially designed” but warrant no more than AT controls ECCN 9A610.x: “specially designed” parts, components, accessories, and attachments that are “specially designed” – 7