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Reform Initiative Becomes Reality

Client Alert | 1 min read | 04.16.13

Today, the U.S. Departments of State and Commerce simultaneously published final rules to take effect in 180 days representing the initial step in completing the first phase of the Export Control Initiative: the creation of a brighter line between the U.S. Munitions List (USML) and the Commerce Control List (CCL). These rules include a uniform, but controversial, definition of "specially designed," a revised version of Category VIII (Aircraft & Related Articles) and the associated new Category XIX (Gas Turbine Engines & Associated Equipment), the unchanged Categories XVII (Classified Articles Not Otherwise Enumerated) and XXI (Defense Articles Not Otherwise Enumerated), and a licensing transition plan for those items moving from the USML to the CCL.


Insights

Client Alert | 3 min read | 04.24.24

Digging Deeper: “American Made” Claims From the Tenth Circuit’s Decision in I DIG Texas v. Kerry Creager Diverge from FTC Guidance

On April 12, 2024, the Tenth Circuit issued a decision in I DIG Texas LLC v. Kerry Creager, which analyzed country-of-origin claims in a manner that diverged from the well-established Federal Trade Commission’s “Made in USA” policy....