We have a thermal imager that is installed within a bigger system. Thethermal imager is ITAR controlled. The imager is only accessed if/when afield technician from the manufacturer is sent out to work on it orinstall/de-install. My questions is about the use of the bigger system that contains theimager. Do I need to control access […]
Our company is French owned. For cost saving purposes our parent company inFrance is looking to combine our US database with that of theirs and havethis one data base reside in Paris with a possibility of it beingserviced/handled by a 3rd party provider. We have homeland security product,controlled under EAR as well as items that […]
If we are working on a project with a company who manufactures ITAR items and our US office’s only involvement on the project will be to place purchase orders and handle the payments in the US ( the foreign office of our company will be listed on the ITAR manufacturer’s TAA as the party that […]
Question: Our company is French owned. For cost saving purposes our parent company in France is looking to combine our US database with that of theirs and have this one data base reside in Paris with a possibility of it being serviced/handled by a 3rd party provider. We have homeland security product, controlled under EAR […]
Question:In 2006 we received a license for the an ITAR controlled item we purchased from a vendor. The vendor has since obtained a favorable ruling on their CJ putting the items under Commerce jurisdiction under eccn 3A001e.4 Our foreign office needs to return one of the items approved under the license we obtained in 2006 […]
Question: It seems that over recent years I have seen a few government prosecution cases regarding the comparatively specific regulatory definition of Public Domain in the ITAR (as opposed to a somewhat broader defn under EAR for ‘publically available’, for example). But I am not a lawyer, and don’t have access to those jungle drum […]
Question: Question: how is foreign origin defense/military technical data & hardwaretreated for ITAR purposes? The definitions of “defense article”& “technical data” in 120.6 & 120.10 do not specify that the items mustbe “US origin”. But certainly foreign person designed foreign origin data &parts sitting in a foreign country is not subject to ITAR. So I’m […]
Question:Need guidance on scrapping/disposing of ITAR hardware. Does anyone have a procedure or guidance from DDTC? 1) Scrapping within the U.S. – I assume that building into your contracts with the scrap yard, trucker etc. that only U.S. citizens are employed, no issue here. 2) Scrapping/disposal OUTSIDE the U.S. – U.S. export was made legally […]
Question: We have learned that several CBP ports have issued public bulletins orpipelines giving the policy on processing entries with ITAR exemptions. Wehave the public bulletins from CBP in Chicago and Buffalo. Do any other CBPbulletins or pipelines exist on this issue
Question: Does it seem plausible that an EEPROM would fall under USML XI(c)??: “Components, parts, accessories, attachments, and associatedequipment specifically designed or modified for use with the equipmentin paragraphs (a) and (b) of this category, except for such items as arein normal commercial use” Our vendor is saying their low cost EEPROM fall here b/c […]
Question:Can any of the ITAR experts in the membership advise what the expression “ITAR cleared” means?
Question:Hi ICPA people…could you please forward this easy peasy question to the membership? Thanks a bunch ITAR Part 120.10 states, when defining ‘technical data’, that is is Information, other than software as defined in Sec. 120.10(4), which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance or modification of defense articles. […]
