((a)) ** Issuance; content** To promote greater certainty regarding the application of the antitrust laws to export trade, the Secretary, with the concurrence of the Attorney General, may issue guidelines—
((1)) describing specific types of conduct with respect to which the Secretary, with the concurrence of the Attorney General, has made or would make, determinations under sections 4013 and 4014 of this title, and
((2)) summarizing the factual and legal bases in support of the determinations.
((b)) ** Administrative rulemaking requirements not applicable** shall not apply to the issuance of guidelines under subsection (a).Section 553 of title 5