Comment: One commenter stated that the "Reason for Control" table in ECCN 7A006 indicates that MT controls apply to commodities that meet or exceed the parameters of 7A106. It appears that, by definition, all items in 7A006 meet or exceed the parameters of 7A106; therefore this language should be removed.
Response: BIS believes that this language is needed because of the longstanding order of review of non-600 series ECCNs, wherein one reviews ECCNs within a category in order. ECCNs with a 0 as the third character follow the Wassenaar Arrangement Dual Use List text. ECCNs with a 1 as the third character generally follow the MTCR text. When the two regimes have identical text about a particular item, the MT reason for control is included in an ECCN with the 0 as the third character. However, when the MTCR text differs from the Wassenaar Arrangement Dual Use List text, the reference to the parameters of the MTCR based ECCN are used to identify items in the text of the ECCN with the 0 as the third character to be precise. This system is used throughout the EAR. Therefore, BIS is making no changes in response to this comment.
Comments Concerning License Exception STA
Comment: Some commenters noted that exports under STA are likely to be in support of foreign defense programs. One commenter recommended the proposed language for the License Exception STA consignee statement set forth in the
One commenter proposed allowing use of STA based on the consignee's assurance that the appropriate U.S. government authorization would be obtained before sending the item outside the STA eligible countries. Another commenter proposed allowing some kind of use of STA on a program basis.
Response: BIS intends that the U.S. government will have authority to license shipments under STA that will not be limited to the end users specified in
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