While the free BIS online decision tools such as the Commerce Control List (CCL) Order of Review Decision Tool can be helpful in understanding the steps and decision points required, it is only for those USML items that you have already determined are moving to the CCL. Our solution goes much further, covering both the DDTC and BIS portions of the Order of Review. Beyond providing guidance, it actually helps organizations reclassify products, parts, and technology previously on the USML and subject to the ITAR into their new USML categories or CCL ECCN numbers under the EAR, greatly reducing the amount of effort and time required by your key knowledge workers. It also creates a complete, defensible audit trail.
The Visual Compliance Export Control Reform Research Center presents all the required information (including the new rules for "Specially Designed" and the "catch and release" process) in an easily accessed intuitive format that makes thorough reclassification research much less of a struggle.
The Visual Compliance Export Control Reform Product Matrix enables your company to implement a methodical automated reclassification workflow and build a defensible audit record. Easily store items undergoing reclassification and communicate the information across the organization.
Visual Compliance clients are already using this solution, improving the quality of their reclassification decisions and enjoying the savings. Initial client analysis results we received indicated that reclassification of a given number of parts can take as little as one tenth the time using the Visual Compliance Export Control Reform solution compared to manual methods. Clients also report increased confidence in their ability to follow the Order of Review correctly.
Regardless of your company's size, if you deal with defense-related goods controlled by the ITAR, the Export Control Reform (ECR) initiative will increase your compliance costs and may expose you to risk if inadvertent errors occur. You have to determine and implement the required changes for all of your products according to very specific procedures (the "Order of Review") recommended by the Bureau of Industry and Security (BIS) and the Directorate of Defense Trade Control (DDTC). These authorities also recommend that you document your process and decisions in order to be able to prove due diligence.
The BIS/DDTC Order of Review is an arduous sequence of steps that involves repetitive exhaustive reviews of both the old and new regulations for each item or range of products. It is a detail-intensive procedure that you must master from the onset or risk facing even bigger problems in the future.