ITAR Lawyer - Commodity Jurisdiction Home | Practice Areas | Lawyers | Insights | Contact

Author Information

Christopher Stagg was a senior member of the policy and commodity jurisdiction sections at DDTC from August 2010 to September 2013.

At DDTC, he was also the deputy lead on Export Control Reform where his responsibilities included reviewing public comments, revising the U.S. Munitions List, and updating key aspects of the ITAR.

Mr. Stagg provides strategic and practical legal counsel to clients on export control laws, including the impact under Export Control Reform.

Contact Information

Christopher B. Stagg
Stagg P.C.
521 Fifth Avenue
17th Floor
New York, NY 10175
D: (212) 518-4854
F: (888) 824-3015



Toolkit for Writing Public Comments on Export Control Reform

Christopher B. Stagg   May 4, 2015

Stagg PC is proud to release this complimentary toolkit for writing public comments on proposed rules involving Export Control Reform.

This toolkit provides general drafting guidance and tips to assist organizations with preparing public comments in response to proposed rules for Export Control Reform under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). 

Responding to proposed rules with public comments is the primary method for influencing how the government will implement export control regulations.  It is also a key method for seeking clarity over the intended meaning of the proposed regulations.

This toolkit concisely summarizes some of the best practices for writing public comments.  It is based on my experiences at the U.S. Department of State in writing regulations under the ITAR and EAR for Export Control Reform, and in reviewing industry comments of proposed rulemaking.

To download a copy of this toolkit in Adobe Acrobat PDF, click here.

* * * * * * * *

How We Help

Our firm can advise your company on how to use the public comment process to advocate its interests to the U.S. Government. In particular:

  • We write persuasive public comments to proposed rules concerning the ITAR and EAR, including the U.S. Munitions List and Commerce Control List.

  • We advise companies on the government's likely objections to its proposed alternative, and we offer ways to potentially overcome these objections.

  • We review how the proposed rule will affect the company, including other related proposed or final rules that may impact the client.

  • We counsel companies on how the government reviews the public comments and the government's key interests to provide sound positions by the client.

  • We balance the detail that is sometimes required to make the client’s argument by not disclosing proprietary information, as the public comments are made publicly available.

  • We advise companies on what they can do if they have missed the opportunity to comment on a proposed rule and the rule is about to go final or is final.

To learn more about Stagg PC's export controls practice and how it can help your company, please click here.

* * * * * * * *

The materials presented in this article are for general information purposes only and do not constitute legal advice or establish an attorney-client relationship.


© 2015 Stagg P.C. All Rights Reserved.