Question: I have heard in the past that an item can have both an ITAR designation and an ECCN designation – but that when this occurs, ITAR trumps EAR. The license would have to go through State. Is it correct that an item that is ITAR can also have an ECCN number, assuming that most […]
Question: The recent debarments by DDTC of certain big name forwarders apply only to the listed locations. Are any other companies having internal dialogs about making business decisions not to use other locations of the forwarder (i.e. if only the Albanian location was debarred, are you considering not using their locations in Estonia also?). I […]
Question: I have a impeller and I need to to know if it is subject to ITAR. I verify the information in 121 Munition list but it only states propellers. *************
Question: We have a customer in the Middle East that is requesting to send a part to the US for repair. The part is manufactured in Canada and is controlled as ECL2-10 under Canadian Law. I have been instructed that this part would fall under the ITAR for the export back to the customer, we […]
Question:Looking for clarification of the interplay between DSP-5, TAAs, and MLAs in offshore procurements. ITAR 124.13 provides good guidelines for licensing of offshore procurements via a DSP-5. Pretty much the technical data being is just that data that is required for bid purposes for hardware that is “build-to-print”. In some cases additional information (not […]
Question:Can any of the membership please advise process to begin handling Classified ITAR regulated goods. How long does this take and how involved?
Question:For the ITAR experts: The 120.21 definition of an MLA is “..an authorization to manufacture defense articles abroad”. So they key difference between TAA and MLA seems to be the granting of manufacturing rights to a foreign party as opposed to NOT granting manufacturing rights. So if I need to send manufacturing information (technical data) […]
Question:We just received an RFP from a defense contractor where we would be a sub under their DARPA BAA. Included is their company’s form specifying that all technical data and computer software generated under this order shall be furnished with unlimited rights as defined in the first two DFARS clauses below. The third clause below […]
I’d like to ask the membership on how they handle the Permanent Importation ofDefense Articles subject to jurisdiction by ATF 27 CFR part 447.If defense item being imported is subject to US Munitions Import List and itsCategory has been “deleted” as inapplicable to imports, thus no Import permitrequired, the question is: How does the membership […]
Question: Hypothetical: US Company A has a wholly-owned foreign UK subsidiary, Company F, that has designed, developed and manufactured a military vehiclecompletely independently of U.S. content, U.S. engineering, U.S. know-howand U.S. parts, manufacturing, etc. Company F wishes to license the vehicleand its technology to Company B located in a different foreign country(Country X) for sales […]
Question: Can anyone explain the proper way to dispose of scrapped ITAR relatedparts? Some these parts may be rubber, plastic or even metal. I know that we must keep a record and destroy the parts unusable but, isthere anything in the regulations that specifies how these types of itemsmust be destroyed? I have been told […]
Question: Can anyone explain the proper way to dispose of scrapped ITAR related parts?Some these parts may be rubber, plastic or even metal. I know that we must keep a record and destroy the parts unusable but, isthere anything in the regulations that specifies how these types of itemsmust be destroyed? I have been told […]
