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 […]
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 […]
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 […]
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 […]
QUESTION: My company does not normally deal with ITAR issues so looking for some guidance from the community. We have been contracted by a government agency to test components controlled under the ITAR and will send one of our engineers to the customer site to perform the training. We are being asked to complete the […]
QUESTION: For those who have been contacted by “one of the big couriers” (to remain un-named) US customs brokerage, about ITAR violations they created on your import declarations for temporary import license exemptions (22 CFR 123.4), how are you handling the situation? =========== Answers: We filed disclosures with both CBP and DDTC. =========== Hi, There […]
