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U.S. Department of State

SUMMARY: Transfers of Chemical Weapons Convention (CWC) chemicals between the Commerce Control List and the U.S. Munitions List.

On November 27, 2002, the Department of State issued an amendment (22 CFR Part 121) of the International Traffic in Arms Regulations' (ITAR) U.S. Munitions List (USML). As it includes developments pertaining to Chemical Weapons Convention (CWC) scheduled chemicals, the amendment contains three significant changes that impact BIS's CWC program.

  • Chloropicrin (CAS 76-06-2) has been moved from the USML to the Export Administration Regulations' (EAR) Commerce Control List (CCL). Chloropicrin is now classified at export control classification number (ECCN) 1C355. No license is required for exports to CWC States Parties but an end-use certificate (EUC) is required to be submitted to BIS for exports to states not party to the CWC. See Section 745.2 of the EAR for EUC requirements.
  • Three Schedule 1 Chemicals have been moved from the CCL to Category XIV of the USML (i.e., QL, DF and Ethylphosphonyl diflouride).
  • Three Schedule 2 Chemicals have been moved from the CCL to Category XIV of the USML (i.e., Methyl phosphonous dichloride, Methyl phosphonous diflouride and Methyl phosphonyl dichloride.
  • For chemicals on the USML, exporters must comply with Department of State licensing requirements contained in the ITAR. Note that Schedule 1 and 2 chemicals may not be exported to states not party to the CWC.
  • Ricin and Saxitoxin are now the only Schedule 1 chemicals remaining on the CCL. The advance notification and licensing requirements for ECCN 1C351 remain unchanged for these chemicals.

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