International Trade Law News

As previously reported, it is taking the Bureau of Industry and Security (BIS) longer than expected to prepare the numerous public comments on the proposed changes to the "deemed export" rule for posting on the Bureau's website. BIS received 309 comments totaling more than 1000 pages of text. The following is a breakdown of the origin of the submissions:

67% from universities;
15% from industry and other trade associations;
9% from private companies;
9% from individuals and others.

Virtually all of the comments were extremely critical of the proposed use of a foreign national's country of birth as a criterion for a deemed export license. The general consensus is that the benefits of such a change do not outweigh the costs of implementing such a rule. As a result, it appers unlikely that BIS will adopt the Inspector General's proposed change.