Stagg Noonan LLP Publishes Client Alert on Export Control Reform: The Strategic Commodity Jurisdiction (CJ) Request

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Law firm publishes important client alert concerning the commodity jurisdiction process that determines whether items are controlled by the Department of State (ITAR) or Department of Commerce (EAR)

We've already seen significant interest by our clients to take a more proactive approach. - Christopher Stagg

The law firm of Stagg Noonan LLP has published a client alert regarding how to use the commodity jurisdiction (CJ) procedure strategically and proactively in light of the revisions taking place to U.S. export control regulations under the ongoing Export Control Reform initiative.

The CJ procedure, under section 120.4 of the International Traffic in Arms Regulations (ITAR), is an inter-agency process that involves the Departments of Commerce, Defense, and State. A CJ is a government determination as to whether an item is subject to the ITAR, Export Administration Regulations (EAR), or by the legal authorities of another government agency.

The client alert notes that “manufacturers and exporters should consider using the CJ process more for proactive and strategic purposes.” The client alert further notes that "There are four primary types of proactive and strategic CJ requests,” which the article then describes.

“This is an important area. With the revisions taking place to the U.S. Munitions List, the CJ process can now be used in more strategic and anticipatory ways,” said Christopher Stagg, who authored the client alert and previously handled CJ requests at the Department of State.

"We've already seen significant interest by our clients to take a more proactive approach," Stagg added.

Mr. Stagg was with the Directorate of Defense Trade Controls (DDTC) from 2010 to 2013 where he was a key member of the CJ section and was directly involved in more than 500 CJ determinations and appeals. Mr. Stagg also authored the revisions to the CJ process for Export Control Reform under sections 120.3 and 120.4 of the ITAR.

Mr. Stagg is a Partner at the law firm of Stagg Noonan LLP where he advises clients on the ITAR and EAR, including commodity jurisdiction (CJ) requests, reconsiderations and appeals.

A copy of the client alert can be obtained from the firm’s website at

About Stagg Noonan LLP

Stagg Noonan LLP provides a unique service to its clients as a leading law firm and thought leader on U.S. export control laws with extensive experience in the areas of the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR).

The firms lawyers have extensive legal experience and are former senior regulators from the Directorate of Defense Trade Controls (DDTC) at the U.S. Department of State who were responsible for administering, enforcing, and revising the ITAR.

With its deep understanding into how the regulatory agencies operate and function, the firm offers special strategies to its clients to solve their critical issues before the U.S. Government.

The firm serves clients located throughout the United States and internationally. Its clients include: defense prime contractors and subcontractors, aerospace companies, cybersecurity and intelligence related software companies, defense information publishers, and educational institutions.

Stagg Noonan LLP is a member of the National Defense Industrial Association (NDIA).

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Christopher Stagg
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