Question: We are a wire producer, who manufactures wire for many applications. Most of our products are used commercially, but some may find their way into military applications. Everything we make is made to order, meeting specific specs for tensile strength, alloy composition, and of course size. These technically aren’t modified and they are not […]
Question: Would any of the members have an example of an ITAR visitor’s log? Also, does any member can shared a generic or basic training on ITAR to give to our associates? ************ Answers: You might want to look at the attached. If it fits the requirement please feel free to use the form. Visitor Log
Question: Does anyone have a template letter to send to distributors to remind them of US export regulations and restrictions on exporting to sanctioned parties? ========== Addl Answer: I have seen many such letters/ contract provisions and have drafted a few of them myself for clients. Most of the template documents that I have seen […]
Question: We have ITAR controlled engineering drawings saved on a access restricted shared drive on our server (located in the US). When offsite, our Engineers have the ability/authority to VPN in to our system and then access any of their files that are located on the shared drives. None of these files are stored on […]
Question: Is anyone aware of any benchmarking studies on how ITAR-registered companies protect their ITAR tech data from foreign,unlicensed owners? ******** Answers: Simple solution is have a dedicated server for ITAR tech data and have strict authorization process in place as to who is authorized access and what they can do as well. So everyone […]
Question: Does anyone know of an alternative to the DSP-61 that takes less time? I am asking on behalf of a Swiss company that wants to temporarily import adual-use item to demonstrate to US customers. **************** ANSWERS: If they can meet the requirements, exemption 123.4(a)(3) would be apossibility that (if the conditions are met) cover the […]
Question: I have a question related to ITAR registration. I am doing the ITAR registration, form DS2032 for the mother company (corporate headquarter), I was wondering do our subsidiaries have to submit their own applications also? *************** ANSWERS: DDTC requires that subsidiaries be included under the corporate registration. Each subsidiary may wish to have a […]
Question: Would anyone be willing to share a copy of an ITAR internal training presentation? *********** Answers: As a result of Export Controls Reform, much of this has been/will be changing. Might be best to wait until all the dust settles. Right now, the USML is a hybrid of legacy application design vs. a positive […]
Question: One of our US research facilities has some ITAR items on site that they use for testing. They will soon be finished with the testing and want to get rid of the items. What are our options? Can we dispose of the items? If so, what is the recommended method? Can we send back […]
We have a supplier that manufacturers Solder Stencils for ITAR circuit card production. Is this supplier required to be registered with DDTC? ANSWERS: Yes. They should register with DDTC. ************* Remember, “use” should not be considered when classifying product under the ITAR. The question you need to ask is; was the […]
Our products transitioned from ITAR to EAR regulations in January. The goods now have a 600 series ECCN and is controlled for RS, UN and AT. Can we display the goods at domestic trade shows? The demo our marketing team is working on will show a cutaway (technical data). Do we need to […]
QUESTION: Question: I have an ITAR unclassified article to be returned for software upgrade. Does software upgrade constitute an upgrade whereas we would use exemption 123.4(b) or can we use 123.4(a)? The general consensus here is that if the upgrade does not change the basic performance of the item then 123.4(a) would […]
