When Does This All Go into Effect?

Amazingly, this massive rule states that it is effective on February 24, 2022, thereby continuing the prior Administration’s practice of making rules effective when they appear on government websites as opposed to the Federal Register.

But the rule does contain two “savings” clauses:

  • The FDPR rules go into effect on March 26, 2022.
  • All the other rules (for example, the licensing requirements for items subject to the EAR that fall under Cats 3-9) go into effect on the date the rule is notified for public inspection in the Federal Register, which was February 24, 2022, so not much of a savings clause unless your items were en route to a port of export, reexport, or in-country transfer on February 24.