US Approves New Policy on Exports of Unmanned Aerial Systems

On April 19, 2018 the U.S. Department of State announced that the President has approved a new policy in regards to the export of unmanned aerial systems (UAS).  The policy applies to all U.S. origin UAS, including those under the control of the United States Munitions List (USML) and those under the Commerce Control List (CCL).

The policy addresses five major objectives:

  • Increases trade opportunities for U.S. companies
  • Facilitates international partners access to U.S. UAS
  • Strengthen bilateral relationships through UAS transfers
  • Prevent state or non-state actors from gaining capabilities that would undermine the US
  • Prevent the proliferation of weapons of mass destruction (WMD) delivery systems   

Transfer conditions:

  • Armed UAS - transfers may be made via Direct Commercial Sales (DCS) or Foreign Military Sales (FMS)
  • Unarmed UAS - transfers may be made via DCS or FMS
  • Civil UAS - continue to be subject to the licensing requirements and policies of the Export Administration Regulations 

For additional details see the State Department press release:

Contact the experts at GCSG for more information.


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BIS adds Hong Kong documentation requirements for exports/re-exports

On January, 19, 2017 the Department of Commerce, Bureau of Industry and Security (BIS) published a final rule (82 FR 6216-6218) which will require, in certain cases, that documents be obtained prior to exporting to Hong Kong or re-exporting from Hong Kong (HK).  BIS issued this rule to provide more assurance that items subject to multilateral control regimes, that pass through HK, are appropriately authorized to their final destination. 

Export Administration Regulation (EAR) regulated items, controlled on the Commerce Control List (CCL) for national security (NS), missile technology (MT), nuclear non-proliferation (NP column 1), or chemical and biological weapons (CB) will now be required to obtain, prior to export or re-export, a copy of a Hong Kong import license.  If a license is not required the exporter or re-exporter will be required to obtain a statement from the Hong Kong government that a license is not required.

This rule will be effective on April 19, 2017.


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