Additional positive news related to streamlining the efficiency of the export process and export control reform came out of the Bureau of Industry and Security in this morning’s Federal Register. Specifically, BIS has issued a proposed rule that would eliminate use of Import Certificates (IC) and delivery verification (DV) documents with the exception being no changes to the requirement for a China Ministry of Commerce End User Statement (MOFCOM) for controlled exports to China in excess of $50,000. Requirements for import certificates for all other countries will be scrapped if this new proposed rule is adopted. Since ICs take weeks to obtain and are required prior to shipment of licensed dual use commodities, this is welcome news. A few other interesting facets of this new proposed rule include:

  1. The minimum dollar figure that triggers a requirement to obtain a BIS-711 Statement of Purchaser and Ultimate Consignee would be raised from its current level of a $5000 license value to $50000.
  2. Under the proposed new rule the U.S. Department of Commerce will eliminate issuing import certificates as requested by foreign exports of goods shipped to the United States.


The Bureau of Industry and Security is seeking public comment on this new proposed rule. Comments are due by June 9th 2014. Comments may be submitted by any of the following methods:

  • Federal eRulemaking Portal: The identification number for this rulemaking is BIS-2014-0009.Show citation box
  • By email directly to Include RIN0694-AG00 in the subject line.
  • By mail or delivery to Regulatory Policy Division, Bureau of Industry and Security, U.S. Department of Commerce, Room 2099B, 14th Street and Pennsylvania Avenue NW., Washington, DC 20230. Refer to RIN 0694-AG00.


Or you may send in your comments to our office and we will file the commentary on behalf of your company. For more information contact our office (210-757-0618) or e-mail

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