Question: Hello – I’m curious how others interpret the verbiage in USML category XI(c)(1). This USML category controls the following: Application Specific Integrated Circuits programmed for defense articles in this subchapter. When referring to subchapter, does this include other defense articles listed in different USML categories (e.g., USML category IV, XII, XX, etc.) are specifically […]
Question: This may be a newbie question and I am not a newbie but I have not come across this question nor ever had to use an ITAR exemption as we mostly fall under Commerce Dept. classifications: 126.5 – can be used to exempt from need for DSP-5? Cat. III hardware, not SME. I am […]
Question: Is my understanding accurate that 126.5(b) Canadian exemptions allows for unclassified defense article (non-SME) exports from US to a Canadian registered person (company) without the usual State/DDTC export license? The items fall under Category III and are not SME. We have reviewed the 120.15, 120.16, 120.17, 123.22, and 126.1 referenced within § 126.5 . […]
Question: Hello – We would like to confirm if a DSP-5 technical data license is acceptable to exchange build-to-print technology only to a foreign consignee to assemble hardware or if a TAA is required? No defense services will be performed, only build-to-print technology will be shared (no design/development data). Thank you. Answer 1: This scenario […]
Question: We shipped a UAS unit under a DSP-83, this unit cannot be retrieved and has been considered a total loss, the initial voluntary disclosure has been filed, I am now working on the final disclosure and corrective actions. Can our wonderful panel confirm that 1. A DSP-74 will be needed to reconcile the DSP-73 […]
Question: Hello ICPA Members, We utilize the Canadian exemption under the ITAR – 22 CFR 126.5(b) to export defense articles temporarily to Canada and to permanently export technical data to Canada. We are reading Supplement No. 1 to Part 126, Note 14 and see that a semi-annual report must be provided to DDTC. Our questions […]
Question: Question: We manufacture and sell machines that cuts materials (metal, wood, paper, etc.). We have companies all over the globe. If a branch located in the EU sells to another company in the EU, would ITAR apply if that machine is then used to cut metal for arms/munitions, etc? Does this fall under the […]
Question: I know that in general, one has to be registered with DDTC to use ITAR exemptions, but I also recall a couple that did NOT require registration. Which are they? Answer 1: Registration with DDTC is required for anyone who engages in the U.S. in the business of manufacturing or exporting or temporarily importing […]
Question: If you are registered with the Department of State and because you produce ITAR controlled equipment, is there a regulation that states you must have a Technology Control Plan in place, along with a visitor process and screening procedure if all of the entities across the country do not produce ITAR controlled products? My […]
Question: Hello, We are an ITAR Manufacturer, however we are looking at onboarding a vendor to provide coating services, but they are not registered with the DDTC. Can we use a non-ITAR compliance (non-registered) vendor/service provider? Answer 1: Day to day ITAR compliance is about one thing only: preventing unauthorized exports. By handing off your […]
Question: Please provide guidance regarding any controls or exemption for vendors preforming secondary processing (such as coating application) performed on ITAR controlled components or goods. Does the vendor have to comply with ITAR controls and be DDTC registered? Please provide citations. In this case it is a US vendor. Answer 1: The only “citation” you […]
Question: Does the 126.18 exemption apply if employees are dual/TCN of 126.1 countries (e.g. China)? Whether using 126.18(c) 1 or 2 to meet the exemption, it does not seem to prohibit 126.1 nationals; is that correct? Answer 1: China does not recognize ‘dual nationality’ for its citizens even though this rule is not applied universally […]
