January 23, 2020

On January 23, 2020, the State and Commerce Departments issued companion rules amending U.S. Munitions List (USML) Categories I, II, and III (firearms; guns and armaments; and ammunition/ordnance) to more precisely describe items that warrant control on the USML and to transfer items that no longer warrant control on the USML to the Commerce Control List. With the publication of these rules, the State Department noted that: “These final rules significantly reduce the regulatory burden on the U.S. commercial firearms and ammunition industry, promote American exports, and clarify the regulatory requirements for independent gunsmiths, while at the same time prioritizing national security controls and continuing our ability to restrict exports where human rights, illicit trafficking, and related issues may be of concern.” The State Department also published a Fact Sheet outlining myths and facts about the final rules.

These revisions complete the initial review of the USML that the Department of State began in 2011 and the conforming changes made to the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). Both rules become effective on March 9, 2020.

For more information on how these could impact your business, contact:

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