• ITAR Cert’s of Analysis as Technical Data?

    QUESTION: We manufacture ITAR-regulated products that conform to a MIL-spec. Many product quality parameters are outlined in the spec, along with acceptable min/max values. Our customers usually get a Certificate of Analysis (CoA) by email with their product batches as proof of conformance, and this document contains data directly related to those parameters in the […]


    QUESTION: When preparing a DSP-5 and using parcel carriers, do you have to list also the parcel carrier as the foreign freight forwarder section or listing them on the US Freight forwarder section enough? ***************** Answers: You wouldn’t list the US parcel carrier in the foreign freight forwarder section but there should also be a […]

  • ITAR Part 130

    QUESTION: I am looking for best practices in asking suppliers, vendors, and other transaction partners for Part 130 information on Political contributions, fees or commissions.  When in the licensing process does your company ask for this information?  Can members please share their forms for gathering this data?  Thank you. ========== Answer: Suggest questions on commissions […]

  • ITAR

    QUESTION: I work for a company that manufactures a Category XII sighting device. Currently all parts are US sourced. Our Engineering Department is interested in potentially working with a Canadian machine shop to machine two parts for these scopes. The machine shop will not be assembling, nor manufacturing the finished unit (the scope), nor would […]


    QUESTION: Our U.S. designed products are sold out of the U.S. and the U.K.  In accordance with U.S. Export Control Reform, we have reclassified many of our formerly ITAR controlled products to EAR control.  Some have transitioned to 600-series ECCN’s and some have transitioned even to a less-restrictive ECCN.  Some dual use products were already […]

  • Technology Control Plan for Non-Employees

    QUESTION: One of our ITAR/EAR-controlled facilities is sharing office space with a sister company foreign national employees. The employees have access to our facility and share our break room and restroom areas. There is no outside entrance upstairs, so the employees have to access yellow line only areas to get to there work area. What […]


    QUESTION: We have a current customer that wants to be a Distributor is Russia. Since Russia has many sanctioned individuals, I want to ensure we are in compliance and have done our due diligence . The items they will be purchasing are not controlled under EAR or ITAR.   We screen all our customers, vendors, […]


    QUESTION: I have to classify a “Specially Designed” cable that on the one side connected to ITAR’s USML system,controlled by USML CAT-IV(h)(9), and on the other side this cable is connected to a system that is under,EAR’s CCL ECCN 9A604.x.,,Does this cable is indeed controlled under ITAR’s USML CAT-IV(h)(9), or can I apply the 120.41(b)(3) […]


    QUESTION: We are setting up electronic recordkeeping and need to understand if shipping documents (shipping or commercial  invoice) of an ITAR product would be ITAR controlled and must be kept segregated from non-US persons ? ================== ANSWERS: No, as long as there is no export controlled technical information on the shipping documents (which there shouldn’t […]


    QUESTION: Does anyone know of specific cyber security- cloud storage requirements (regulations) for ITAR Data?   Other than the known encryption best practices – is there for example – a requirement whereby if data is stored in a cloud based service – the owner is required to have the keys? (Best practice would be yes- […]


    QUESTION: Some of our engineers will be evaluating ITAR-controlled technology over a period of time. I want to give them an €œITAR Notice€ that can be read before the start of any meeting regarding the evaluation and have the participants sign a statement of confidentiality specific to this technology prior to access. Because we don€™t […]


    QUESTION: I found out that equipment that my product is used in as an “attachment” is on the CCL Alphabetical Control List and has an ECCN number but my product is not on the Alphabetical Control List. While I do not see the name of my product on the Alphabetical Control List  would it be […]