Export Control Reform: Opportunities And Risks For The UAV Industry

Kelley Drye & Warren LLP Paper

Many UAV system, component, and part manufacturers are looking forward to the liberalization of export controls proposed under the President’s Export Reform Initiative. Under the proposed changes, many items currently controlled under the U.S. Munitions List (USML) and International Trade in Arms Regulations (ITAR) will be transferred to the Commerce Control List (CCL) and Export Administration Regulations (EAR). The transition promises to release many items, particularly certain parts and components, from restrictive export controls under the ITAR to generally more liberal controls under the EAR. These changes will likely bring new export opportunities to the UAV industry, but they will also present challenges in the form of increased complexity and enhanced enforcement.

The following article discusses both the risks and benefits of reform, as well as considerations that out to be made for compliance as reforms are incorporated into formal rules.