NOPR versus SNOPR: Proposed Changes to Key Provisions 

Destination classification

NOPR: The NOPR proposed to change the 

classification of 3 countries with growing nuclear 

trade to generally authorized from requiring 

specific authorization. It was also proposed that 77 

countries with limited nuclear trade, with the 

exception of Mexico, switch from generally 

authorized to requiring specific authorization. The 

proposed change did not affect the classification of 

117 country destinations.

SNOPR: The SNOPR proposes to extend general 

authorizations to existing projects in Mexico and 

Chile, as both countries have Project and Supply 

Agreements. Country reclassification to general 

authorization may be considered if the United 

States has brought into force a 123 Agreement for 

Peaceful Nuclear Cooperation with a country not 

on the generally authorized list. 

Foreign employee access to technology:

NOPR: Specific authorization would be required 

unless employee is a citizen of a generally 

authorized country. 

SNOPR: Foreign employees from countries that 

require specific authorization would be generally 

authorized subject to certain conditions, including

access expressly authorized in accordance with 

NRC requirements.

Scope of Commercial reactor assistance covered

NOPR: Proposed to broaden Part 810 scope from 

“production reactor” to “nuclear reactor” 

technology. 

SNOPR: Proposed to clarify that Part 810 covers

reactor technology related to special nuclear 

material (SNM) production. 

Operational Safety

NOPR: Proposed to eliminate “fast track” 

authorization for operational safety assistance but

proposed to retain it for nuclear emergency 

assistance. 

SNOPR: Would retain fast track authorizations for 

both and tie the definition of “operational safety”

to established safety standards. It also would 

permit authorized safety exchange and 

benchmarking programs. 

Back End Activities

NOPR: Separation and reprocessing of special

nuclear material are back-end activities that have 

always been covered by Part 810. The NOPR 

proposed to expressly cover specific additional 

back-end activities. The purpose was to cover 

them because they can be a part of a separation 

and reprocessing program. 

SNOPR: The SNOPR would make no change to the 

current status of back end activities or the text of 

Part 810. Back end activities related to special 

nuclear material reprocessing would continue to 

require specific authorization. Otherwise, backend activities would not be subject to part 810. 

Other SNOPR Proposed Changes

• Commerce and State approved transactions would be exempt, as NRC approved transactions are 

now. This proposed change would help ensure there is not duplicative regulation.
• Medical isotope production was potentially covered by the NOPR. The SNOPR would expressly 

exempt all production, except for Moly 99, which would be generally authorized. These are highvalue activities with little proliferation risk.

• Activities carried out by IAEA personnel would be generally authorized except for employees from 

restricted countries working on sensitive technology

• Transfer of public information was proposed to be generally authorized under the NOPR. The 

SNOPR proposes new standardized definitions of public information that conform to other export 

control regimes and would make transfers exempt. 

• Definitions and terms: SNOPR proposed to add or revise terms to conform to proposed substantive 

changes and other export control regimes.