Question: Our company is re-structuring and I have been asked to recommend how to organize the global trade compliance department to support all of our businesses. My question is specific to whether ITAR should be a stand alone dept. or should be rolled in with the existing Export team (IMS/EMS, Policies, Audit, Training, etc.). I appreciate […]
Question: I was hoping someone could she some light on the importation of ITAR articles returning from a demonstration. Since the items left on a DSP73 and are returning, we should have the DSP73 decremented at the time of entry. Should we also claim 9801.00.10 for US goods returned on the entry?
A registered manufacturer of ITAR controlled goods sells a defense article to a domestic customer. The DCS is on the documents notifying the domestic buyer that the item is controlled. What is the liability for the manufacturer if the domestic customer exports the product without obtaining a DOS license? Is the manufacturer required to obtain […]
Question:I am being told that if an items is used in a Military application, but not designed specifically for that application we do not have to register with the DDTC? Â Example oil seals used in MRAP vehicles or developed for commercial aircraft that can be used in military aircraft.
ITAR question for the experts in the membership. Our company makes standard commercial grades (chemicals) for a wide variety of industries. We sell to many companies in several countries, none military-related. We also sell through distributors. Most distributors are non-military related but a few are. But we always sell them the standard grades – no […]
I have an ITAR item. I have a component in that item, and the component is only subject to the EAR. Can I ship the component under the EAR even if I’m shipping it for the purposes of repairing the ITAR item or would I need State’s permission in that case?
I was looking to get some feedback on a ITAR question that has surfaced. Has anyone been through an audit mandated by the State Department? I understand that many audits are actually the result of self disclosures but I am trying to understand if the audit would consist of a complete scrub. For example, if […]
My company manufacturers some military spec electronics (Mil spec 883-B). Products can be used for either Military or Commercial (Dual-use). If not “specifically designed or modified” for military applications, only assembled to military spec, would the commodities be subject to ITAR?
Do you have to send the SED to ODTC when using exemption 22CFR 123.4(a)(1)? If so, does the SED need to be signed by customs or do you just send a copy of what was sent with the shipment? I see the requirements for customs, but I do not see the requirement for ODTC. In […]
How have other members handled provisos that are unclear? Have you used general correspondence or a DSP-6003 Request for Reconsideration of Unclassified Provisos? What is the average turn around time for this response from State? When do you involve outside counsel in this process ?
We are a US company that makes connectors which can be used in a variety of applications. We have a baseline connector product that is modified specifically for each and every individual application. Based on a strict interpretation of ITAR, therefore, modifications of our baseline product for military applications (i.e., applications on the US Munitions […]
Does anyone know what section within the ITAR and the U.S. EAR addresses in-transit shipments? We have a facility in Canada that ships defense articles to Latin America. They have been told that anything traveling through the U.S. will require a U.S. export license even if the plane is only stopping for refueling. The same […]
