• UK Controlled technology

    Question: We have a product that we build in the UK and falls under UK dual use controls, it ships from the UK under a UK OGEL  Under the US controls, this item is an ITAR product. For this reason, we don’t sell the product to the US market because it makes returns and product […]

  • Export Certifications for EAR/ITAR

    Question: Hi, I’m in the process of adding export training to my existing base of import knowledge to round out my resume.  I’d like input regarding any trainings/certifications that would be most relevant and impactful when seen by future employers.  Does anyone with an export background have suggestions? Answer 1: Hi there. Content Enablers offers certification […]

  • USML Category XI(c)(1)

    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 […]

  • 126.5 Canadian exemption

    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 […]

  • 126.5b Canadiam exemptions

    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 . […]

  • Licensing

    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 […]

  • Total loss UAS that was exported under a DSP-73

    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 […]

  • Canadian Exemption

    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 […]

  • ITAR & End Use

    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 […]

  • ITAR exemptions

    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 […]

  • Technology Control

    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 […]