Comment: Commenters stated that more information about the order of precedence or order of review was needed for the public to be able to classify items reliably. Many items might be reasonably classified under a USML category or an ECCN, more than one ECCN, or more than one ECCN paragraph.
Response: BIS received comments along this line in response to other proposed rules. The
Comment: Commenters expressed concern that moving items from the USML to the CCL would increase the number of licenses that some companies would need for two reasons.
First, in many instances, the
Second, license exceptions under the EAR do not apply to some transactions that would be exempt from license requirements under the ITAR. Two solutions were proposed. First, amend license exceptions under the EAR to make sure that they cover transactions that would qualify for an exemption under the ITAR. Second, create a new license exemption that authorizes using ITAR exemptions for transactions that are subject to the EAR.
Response: The potential problem of needing both a DDTC and a BIS license for a single transaction is sometimes referred to as the dual licensing issue. BIS's and DDTC's
Comment: A commenter recommended several steps to deal with the expected increase in the number of license applications to be submitted to BIS, such as: Increase staffing levels; "enhance" the DOC licensing process to reduce cycle times; include reviewing agencies in efforts to streamline the license application review process; and leverage lessons learned and best practices from the
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