• Courier returns if ITAR goods

    QUESTION: Hello all we make a very small product that ships almost exclusively via courier as this is most cost effective.  I’m sure as we have all experienced, there is not a lot of control over how your package is handled once it has been picked up and violating the ITAR doesn’t seem to be […]


    QUESTION: What are the exact semantics of claiming the ITAR 123.4(a) exemption upon US import?  There is no box/space for it on the 7501.  So how exactly is it done, since the entries are all filed to CBP electronically?  ================================================================ Answer: When Importing with a ITAR license (DSP-61 or DSP-73) or exemption, the DDTC PGA […]

  • ITAR Broker Work from Home = Company Facility

    QUESTION: Our company is considering hiring an EU foreign employee through an employer of record to work on business development. The ITAR brokering definitions in §129.2 state brokering activities do not include activities by a  regular employee §120.39. The prospective employee could meet most of the definitions in §120.39 (a)(2) except where the individual works […]


    OT Fact Sheet: Origin Certification Requirements QUESTION: I have question in regards to submitting a TAA and TDL(Technical Assistance Agreement/Technical Data License). I currently have an active TAA for a part that was ITAR controlled at the time the TAA was created but now the part has become ECCN controlled under ECCN 9A604.x. My TAA […]


    QUESTION: Companies that manufacture ITAR products in a maquiladora/IMMEX – anyone know how many do this, is it common? How do they set it up, avoid risks? **************** Answers: You will need to obtain a Manufacturing License Agreement from the DDTC. See 120.21 of the ITAR ***************From my understanding based on past experiences, rare or […]


    QUESTION: Looking for guidance from the membership.  A heatsink of standard aluminum is die cast into a very specific, unique shape on the exterior and the interior in order to allow electronics to fit inside the heatsink, and for the heatsink to fit into an end item that is a power supply.  Heatsinks are, in […]

  • Historical ITAR items

    QUESTION: In today’s export world for classification how would the membership, via the order of review classify an ITAR item invented pre-export reform using today’s export regulations/ITAR regulations, with the intent of determining if the item would still be ITAR today?  I would like the most relevant questions or go/no go criteria so that the […]


    QUESTION: Looking for a checklist of questions to ask, (or something equivalent) that are asked/used with the intent of determining if a product is ITAR controlled, or not. Can the membership please provide the top 5 most relevant questions in order of importance you would ask in order to determine if an item under review […]


    QUESTION: I just found out that a new section of business is pending for us and the items are ITAR controlled.  When classifying the items we will ultimately manufacture, I know that we must follow the Order of Review, starting with State, then 600, 900 series and then onto the remaining reviews to assign the […]

  • Commercial assemblies for Military End use

    QUESTION: We make cables assemblies for various types of equipment. We use commercial available cable and connectors and then we will cut the cable and attach  the connector as specified by the customer. Some of these are for commercial use,  some go into spacecraft and some go into military equipment.  We are challenged with the classification of the […]

  • ITAR “Specially Designed”

    QUESTION: If you manufacture an item that is a “specially designed” “part” controlled under the ITAR, and that item is unintentionally manufactured out of spec, is it no longer “specially designed” and controlled by the ITAR because it is out of spec? %%%%%%%%%% ANSWERS: Does the out of out of spec item meet the ITAR […]


    QUESTION: We do not produce ITAR controlled items but have been contracted to perform testing at our customer facility that has ITAR controlled technology Do we need to come up with a Technology Control Plan for our engineer or is this normally completed by the ITAR facility? ************ Answers: Long as the employees assigned to […]