Export Compliance Training Re-certification
Export Control Rules
It is unclear how much of this White House initiative will emerge unscathed, but it certainly illustrates the caveat emptor nature of export control rules. Change is a constant. Therefore, it is incumbent on all PSI employees to stay abreast of relevant changes to the ITAR and the EAR regulations that govern so much of what we do here.
Update training on the ITAR and EAR is not only a good idea in a rules-compliant firm like PSI -- it is also a matter of law and best-practice for affected employees to undergo at least annual training.
Just as when joining PSI, all employees will be provided an online set of study materials, kept up-to-date by PSI’s Export Compliance Officer, and then will be required to take and pass an update test demonstrating they are remaining current in their knowledge of essential rules and procedures.
Important: The old "AES" system at AESdirect.gov has been replaced by the new "Automated Commercial Environment", or "ACE". Most export situations require logging into the company's ACE account prior to the export in order to file an appropriate "EEI", or electronic export information. At PSI this is the responsibility of our export compliance officer. (For those who worked with exports back in the paper licensing days, know that the EEI takes the place of the old "SED", or shipper's export declaration.)
MAJOR changes are underway in our export rules
It is called “Export Control Reform”, or “ECR” for short. The ECR revises some categories on the USML and moves some items to the new "600-series" of ECCNs in the EAR's Commerce Control List ("CCL"), and is incrementally being implemented. The primary intent of ECR is to move from the USML to the CCL those items that, in the view of the regulators at State and Commerce, no longer warrant the extra control of the ITAR. These items moving to a 600-series ECCN remain military items, and do not become commercial items. Rather, the jurisdiction for export purposes shifts to the EAR, with its generally easier and more flexible licensing procedures. The term "600-series" derives from the third character in the new ECCNs. We’ll keep you posted on details, but the changes so far seem to be, by and large, good for PSI.
Proposed ITAR/EAR amendments have been published in the FedReg seeking user comments, and most of them have already been finalized. The first set of changes became effective on October 15, 2013. The export rules governing aircraft were the first out of the blocks, and now in 2024, most parts & components for ITAR-jurisdiction systems have already moved from the ITAR to the EAR for export-jurisdiction purposes. Some PSI products, especially those that are or were subject to the ITAR under USML Category XII(f), remain under that same ITAR jurisdiction. We are closely monitoring these rules, and we will continue training you on them. We’ll keep you posted.
Meanwhile we will continue to train on export control in general, and the ECR in particular -- but don’t panic!
This training is less involved than the initial training. And the test has only 10 questions. Study materials are provided here online, and also a focused study guide.
Export Control Rules
It is unclear how much of this White House initiative will emerge unscathed, but it certainly illustrates the caveat emptor nature of export control rules. Change is a constant. Therefore, it is incumbent on all PSI employees to stay abreast of relevant changes to the ITAR and the EAR regulations that govern so much of what we do here.
Update training on the ITAR and EAR is not only a good idea in a rules-compliant firm like PSI -- it is also a matter of law and best-practice for affected employees to undergo at least annual training.
Just as when joining PSI, all employees will be provided an online set of study materials, kept up-to-date by PSI’s Export Compliance Officer, and then will be required to take and pass an update test demonstrating they are remaining current in their knowledge of essential rules and procedures.
Important: The old "AES" system at AESdirect.gov has been replaced by the new "Automated Commercial Environment", or "ACE". Most export situations require logging into the company's ACE account prior to the export in order to file an appropriate "EEI", or electronic export information. At PSI this is the responsibility of our export compliance officer. (For those who worked with exports back in the paper licensing days, know that the EEI takes the place of the old "SED", or shipper's export declaration.)
MAJOR changes are underway in our export rules
It is called “Export Control Reform”, or “ECR” for short. The ECR revises some categories on the USML and moves some items to the new "600-series" of ECCNs in the EAR's Commerce Control List ("CCL"), and is incrementally being implemented. The primary intent of ECR is to move from the USML to the CCL those items that, in the view of the regulators at State and Commerce, no longer warrant the extra control of the ITAR. These items moving to a 600-series ECCN remain military items, and do not become commercial items. Rather, the jurisdiction for export purposes shifts to the EAR, with its generally easier and more flexible licensing procedures. The term "600-series" derives from the third character in the new ECCNs. We’ll keep you posted on details, but the changes so far seem to be, by and large, good for PSI.
Proposed ITAR/EAR amendments have been published in the FedReg seeking user comments, and most of them have already been finalized. The first set of changes became effective on October 15, 2013. The export rules governing aircraft were the first out of the blocks, and now in 2024, most parts & components for ITAR-jurisdiction systems have already moved from the ITAR to the EAR for export-jurisdiction purposes. Some PSI products, especially those that are or were subject to the ITAR under USML Category XII(f), remain under that same ITAR jurisdiction. We are closely monitoring these rules, and we will continue training you on them. We’ll keep you posted.
Meanwhile we will continue to train on export control in general, and the ECR in particular -- but don’t panic!
This training is less involved than the initial training. And the test has only 10 questions. Study materials are provided here online, and also a focused study guide.