Question: Question: We manufacture and sell machines that cuts materials (metal, wood, paper, etc.). We have companies all over the globe. If a branch located in the EU sells to another company in the EU, would ITAR apply if that machine is then used to cut metal for arms/munitions, etc? Does this fall under the […]
Question: I know that in general, one has to be registered with DDTC to use ITAR exemptions, but I also recall a couple that did NOT require registration. Which are they? Answer 1: Registration with DDTC is required for anyone who engages in the U.S. in the business of manufacturing or exporting or temporarily importing […]
Question: If you are registered with the Department of State and because you produce ITAR controlled equipment, is there a regulation that states you must have a Technology Control Plan in place, along with a visitor process and screening procedure if all of the entities across the country do not produce ITAR controlled products? My […]
Question: Hello, We are an ITAR Manufacturer, however we are looking at onboarding a vendor to provide coating services, but they are not registered with the DDTC. Can we use a non-ITAR compliance (non-registered) vendor/service provider? Answer 1: Day to day ITAR compliance is about one thing only: preventing unauthorized exports. By handing off your […]
Question: Please provide guidance regarding any controls or exemption for vendors preforming secondary processing (such as coating application) performed on ITAR controlled components or goods. Does the vendor have to comply with ITAR controls and be DDTC registered? Please provide citations. In this case it is a US vendor. Answer 1: The only “citation” you […]
Question: Does the 126.18 exemption apply if employees are dual/TCN of 126.1 countries (e.g. China)? Whether using 126.18(c) 1 or 2 to meet the exemption, it does not seem to prohibit 126.1 nationals; is that correct? Answer 1: China does not recognize ‘dual nationality’ for its citizens even though this rule is not applied universally […]
Question: I have been with the company for almost five years in the EO role, I am the one and only compliance department covering two locations and also the EO for an A&D company. I have requested several times for a support person if nothing else train someone to support my role when I am […]
Question: Thought I saw a question on this previously but it does not come up when searching the database. Sales is asking to use a circular logo with “ITAR Compliant” on customer presentations. Inclination is to decline this request. Welcome any good regulatory reference/data/arguments against such a claim. We are DDTC registered, but ….. Answer […]
Question: ITAR Section 123.22(b)(3)(i) states that, “[p]rior to the permanent export of technical data licensed using a Form DSP–5, the applicant shall electronically provide export information using the system for direct electronic reporting to DDTC of export information and self-validate the original of the license.” Is the system DECCS? If so, how is reporting achieved? […]
Question: If foreign parties are in legal possession of US origin ITAR data (received under a license, exemption, TAA), do they need “authorization” from DDTC to send it to US PARTIES (which were not part of any original license/TAA)? Part of me has always taken the position that no authorization is needed to send to […]
Question: Am I remembering correctly that DDTC stopped looking at country of birth as part of the equation in “nationality” determination? In looking at p 71 in the agreement guidelines that seems to be the case. I know there is still the pending ITAR change to align with BIS in that ITAR would only […]
Question: Hello, One of my foreign plants is being asked to participate in an MLA. They were sent just a standard ITAR NDA, with no real explanation of what is happening, what is ITAR etc. Since I know that this is just the first MLA, I want to have a process in place to assure […]
