ITAR Reorganization Rule Set to Go Into Effect September 6 – International Trade & Investment


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The U.S. Department of State’s highly anticipated Interim Final Rule revamping the International Traffic in Arms Regulations (ITAR) is set to go into effect on September 6, 2022.

The Interim Final Rule, originally issued by the U.S. Department of State’s Defense Trade Controls Directorate (DDTC) on March 23, 2022, will revamp and consolidate ITAR definitions. Part of a broader agency effort to reorganize ITAR, this new structure will improve the organization of regulations by concentrating authorities, policies and definitions into separate and logical subsections. removing duplicate text and standardizing section structure and style. The DDTC said the rule does not make substantial revisions to the regulations or impose new requirements, but rather improves clarity.

Prior to this regulation, definitions were generally spread throughout the sub-chapter. Once the rule comes into effect, Part 120 will be divided into three subparts: Subpart A – General Information; Subpart B – General Policies and Processes; and Subpart C – Definitions. This new organization aims to provide readers with a regulatory roadmap.

  • Subpart A – General Information: groups and explains the legislative authority and purpose of regulations to help understand their significance and source.

  • Subpart B – General Policies and Processes: Describes the general processes and policies of ITAR.

  • Subpart C – Definitions: provides a consolidated list of defined terms applicable throughout the ITARs. The DDTC notes, however, that the definitions will not be in alphabetical order.

Part and section specific information and definitions will continue to appear in the applicable part or section of the settlement.

In addition to the changes described above, a list of changes that may be of interest to the regulated community can be viewed here. This is the first of several rules in DDTC’s proposed ITAR reorganization, so DDTC will gradually implement these changes.

On August 17, 2022, the Department of State released and completed the interagency review of a final rule that will revamp and consolidate definitions in the ITAR. Although the final rule has yet to be made public, Buchanan’s International Trade and National Security team is closely monitoring the State Department’s reorganization of ITAR and will keep the regulated community informed of any other State Department action.

The content of this article is intended to provide a general guide on the subject. Specialist advice should be sought regarding your particular situation.

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