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Import and Export Solutions specialises in UK and US aircraft controls.
In
the UK, there is one government department that processes
export licence applications, The Department of Trade and Industry,
Export Control Organisation (DTI
website).
There are two control lists to consider:
- Military, security and para-military goods, software and technology and arms, ammunition and related material
- Dual-use items and technology
In the US, there are several departments dealing with export issues. The main two are:-
-
The State Department
Munitions items administered under:
ITAR - International Traffic in Arms Regulations
(Visit the State Department website)
-
Bureau of Industry and Security
Commerce items (dual-use) administered under:
EAR - Export Administration Regulations
(Visit the Bureau of Industry and Security website)
However,
there is a difference between the two sets of legislation.
In the UK if an item was originally designed or has been
modified for military use then it will generally remain military
even if subsequently used for civil purposes e.g. antique aircraft
still require a military export licence if taken overseas for
an Air Show.
In the US only items that are unique to the military are
usually controlled by the State Department. Items that are subsequently
used by industry are usually moved to the Commerce Department.
However, the ITAR also covers some non-military items if they
are considered sensitive e.g. commercial satellite equipment appears
on the ITAR and requires a munitions licence.
This creates confusions for UK Exporters of US origin aircraft
parts because it is possible to buy commercial aircraft parts
from the US that are considered as military by the UK e.g. C130
and L100 aircraft types.
Export control legislation also affects the civil aircraft industry
– civil aircraft are controlled to certain destinations i.e.
Military users in embargoed destinations and commercial operators
in Iran and Iraq.
There is concern that, civil aircraft will be used by the military
in these countries e.g. Saddam Hussein used civil aircraft to
‘crop spray’ the Kurds in Northern Iraq. Whole communities
were annihilated with chemicals agents.
To add to this confusion, certain avionics and propulsions systems
are also controlled; this is because some of this equipment can
be used or adapted for use in connection with weapons of mass
destruction e.g. inertia navigation equipment.
Import and Export Solutions specialises in controls relating to
aircraft - these controls are covered in our computer
based training packages and workshops.
