ITAR

ITAR

  • ITAR SECTION 123.4

      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 […]

  • ITAR CAT IV SUPPLIER

      QUESTION:   My company builds Category IV ITAR boards.  We a looking at suppliers to create special shipping boxes to ship our boards safely and reduce damage. A new packaging company is requesting that we send them pictures of the board, diagrams, and dimensions so they can create a box specifically designed for these […]

  • ITAR PROCESS

    Question: Our company’s products have, until now, been controlled solely by the EAR. But it looks like we will be dipping our toes into the ITAR puddle soon. Although I have worked for companies subject to ITAR, I have never prepared a company from scratch for ITAR activity.  I want to make sure I am […]

  • ITAR EXEMPTION

    Question: I have the need to get technical data enclosed on hard drives from US to Bahrain.   Unfortunately, there is no time to submit licensing for foreign consignee. Under ITAR exemption 125.4(b)(9) we can have an employee(US Person) hand carry product directly OR ship directly to the US Person(employee).   The Hand carry is pretty clear, […]

  • FOREIGN VISITOR VISIT AND ITAR Addt’l answers

    Question: We sell the ITAR controlled items to US domestic customer (A).  Our US domestic customer (A) sells and exports the ITAR controlled items to their oversea customer (B).  It’s a domestic sale for us. We would like to know if foreign customer B can come to our plant and do the source inspection at […]

  • QUESTION ON ITAR BROKERING

      Question: Here is a question about ITAR brokering that I am putting out to the membership’s ITAR experts and attorneys.  Company A is a registered ITAR exporter,  Company C is a foreign logistics company that sells to a foreign military government, Company B is a foreign company that coordinates the shipment between Companies A […]

  • QUESTION ON ITAR BROKERING

      Here is a question about ITAR brokering that I am putting out to the membership’s ITAR experts and attorneys.  Company A is a registered ITAR exporter,  Company C is a foreign logistics company that sells to a foreign military government, Company B is a foreign company that coordinates the shipment between Companies A and […]

  • ITAR PARTS AT AUCTION

    Question:   What precautions should a company take when sending ITAR components to U.S.    auction houses?   ==========

  • 9801 FOR ITAR RETURNED GOODS

    Question:   Would like to get the memberships view regarding ITAR returns to US. Do most   of you avoid claiming 9801 since most of the items are duty free anyway?   Advantages, disadvantages?   ==========

  • DEFENSE ARTICLE EXPORTED WITHOUT AUTHORIZATION

    QUESTION:   Hypothetical Question….if a Defense Article were inadvertently exported to France without DDTC authorization.  What would be the best corrective action to identify in a Voluntary Disclosure for bring the Defense Articles back to the US to then be properly authorized for export?   **************