Comment on DOS-2012-0020-0001

For updates to the USML resulting from moving products to the 600 series under the EAR, is there any effort by any agency to coordinate ECR with ATF to have a consistent set of changes to the USMIL (import version of the USML) now or in the future? Today, the USML export list and the USMIL import list are reasonably similar to allow industry to handle the movement of defense articles in both directions, for permanent transfer, under a reasonably consistent set of regulations. Post ECR, the importation of defense articles will continue to be regulated under the USMIL although many items will have moved to the EAR under the 600 series. Is it intended that the Government's definition of a defense article continue to be different depending upon the direction of permanent transfer? An example of the added burden to industry is a manufacturer and exporter of defense articles who permanently imports subassemblies that are ITAR controlled for assembly into ITAR end products that are sold domestically (therefore requiring an ATF permit for the original import) and sold abroad (via DDTC licensing). Post-ECR, if the export of these end products is now EAR controlled, that company would still need to review the distinctly different USMIL and continue to request, obtain, and decrement against ATF permits resulting in added complexity internally for tracking, maintainence and training of staff. Is the decoupling of a critical US agency in this multi-agency effort intentional, an oversight, or planned to be addressed at some future date to be consistent with the overall Administration's ultimate objectives?