January 2021 Import/Export Compliance Seminar Series
Even in this time of COVID-19, export transition is still moving. Exporters need to know how the new regulations are working, and what they need to do to keep their export business running smoothly. This mini-conference is being provided by NSSF as an alternative to our usual annual Import/Export Conference normally held in Washington, DC in August. Personnel from BIS, DDTC and ATF will be presenting current information and updates on their various regulations. Both current exporters and new exporters should sign up for these sessions and hear directly from the agencies on important issues.
USML to CCL Transition Training Resources
The final rules to transition export licensing of sporting and commercial firearms and ammunition products to the Commerce Department (Bureau of Industry and Security – BIS) from the State Department (Directorate of Defense Trade Controls – DDTC) were formally published on January 23rd and became effective Monday, March 9, after a federal court in Seattle adopted NSSF’s recommended language for a preliminary injunction narrowly limited to 3D printing but otherwise allowing the final rules to go into effect.
Read the rules here: State Department and Commerce Department.
Training Options:
2020 NSSF IM/EX Webinar Series
The National Shooting Sports Foundation hosted an August 2020 webinar series for exporters. The series featured speakers from the Commerce Department’s Bureau of Industry and Security and offered a look back at the USML to CCL transition’s first months, and what the firearm and ammunition industry can expect moving forward.
We are currently offering the recordings of three sessions:
Session 1 – BIS Licensing – Lessons Learned and Forward Guidance
BIS Licensing staff review licensing from the early applications prior to and since the March 9th effective date of the new rule to the current time and how BIS’ implementation and approach to licensing firearms and ammunition has developed. They discuss licensing best practices and guidance for exporters going forward to help them improve license submissions, which will reduce effort and result in better licenses.
Session 2 – BIS Policy – Rule Interpretations and FAQs
BIS Policy personnel review the issues and situations which have arisen since the March 9th effective date and discuss the FAQs and guidance they have developed to respond to these situations. Many questions have been posed by industry related to classifications, EAR clauses and terms, and regulatory wording and intent in some ECCNs. This session provides information to respond to these questions and explain the FAQs.
Session 3 – BIS/Census – AES Filing Requirements for the new 500 Series ECCNs
BIS and Census review the changes to the AES system to accommodate the new 0x5zz ECCNs. This information includes the specific filing and license codes allowed for the various new ECCNs.
Previously Recorded Sessions
NSSF hosted a one-of-a-kind training session in Hartford, Conn., with the Commerce Department’s Bureau of Industry and Security (BIS). A video recording is now available for each of the NSSF-BIS joint presentations focused on the transition of firearms, ammunition, and accessories from control under the State Department’s Directorate of Defense Trade Controls (DDTC), to the BIS.
Recorded Webinar Series
A 5-part NSSF webinar series with one of the reform’s lead architects, Kevin Wolf, and compliance expert Kim Pritula, President of KMP Global Consulting.
Part 1: Classification under the CCL This webinar focuses on how firearms and ammunition are classified on the Commerce Control List (CCL), and explains how to read the ECCNs and what the different sections mean.
Part 2: Licensing under the EAR and SNAP-R Learn the way licensing is done under the EAR, how it differs from ITAR licensing, and how the BIS electronic licensing system SNAP-R works.
Part 3: EAR Exceptions This training explains the various EAR exceptions and how they specifically relate to firearms and ammunition transitioned to the CCL.
Part 4: Technology and Published under the EAR Understand the controls on technology for firearms and ammunition, and what the EAR term “published” means for these products.
Part 5: “Specially Designed” under the EAR This webinar explains the term “specially designed” and how to review your products against this designation to understand how it is controlled.
Annual Firearms Import/Export Conference
The 2020 conference has been cancelled due to the COVID-19 pandemic.
Save the date for our 19th conference, to be held on August 3 – 5, 2021 at the Trump Hotel, Washington, DC.