Develop Standards for Munitions and Dual Use Items
  • If the control scheme is to involve separate lists for munitions and dual use items, the delineation between the two lists should be clear, especially if each list is separately administered, as at present.

  • The terms defense articles and dual use goods and technologies should be clearly differentiated if the Munitions List is to remain distinct from the Commodity Control List. If a separate Munitions List is maintained, it should only contain (1) items specially designed for a significant and uniquely military application and (2) items that do not have essentially the same performance, capacity, or function as items used for commercial purposes.

Set Time Limits and Dispute Resolution Procedures
  • Clear policy guidance, including guidance on timely procedures for resolving interagency disputes, should be provided to obviate most of the need for legislated deadlines.


More efficient case processing, better procedures for dispute resolution, and greater system transparency are among the potential gains from a revised administrative process. To this end, the U.S. government should take the following steps:

Consolidate Administration in a Single Agency
  • In order to achieve a more rational and effective export control process, the U.S. domestic process should be reconfigured through consolidation of all day-to-day administrative functions in a single agency. Single agency authority for day-to-day functions will have the following advantages:

  • Establish a more rational and consistent regulatory structure.

  • Achieve efficiency in list administration and implementation of regulatory changes.

  • Attain further improvement in license processing.

  • Avoid jurisdictional disputes at the administrative level.

  • Facilitate industry's access to information on export control requirements.

  • Increase efficiency by consolidating the electronic data processing functions of various administrative agencies.

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