QUESTION: I have a question about subcontracting out some ITAR cutting/machining metal work to a vendor who isn’t DDTC registered. Say, hypothetically, we want subcontract out to another company to machine to spec (drawing is controlled technical data) a USML specially designed part who we know isn’t DDTC registered. We own and supply the metal […]
QUESTION: My company does not manufacture any ITAR items so I don’t have much experience in this area other than what I have learned in seminars and need the assistance of the membership We are performing a testing service of an ITAR controlled item for a Federal Government Contractor and received an Export Compliance Certification […]
QUESTION: The secure message sent from the contractor states the attachment of the email contains technical data, export of which is restricted by ITAR or EAR. My first thought was to segregate all foreign nationals in the company and not allow any access to anything involved in the project, however, when I read the Certification […]
QUESTION: We have some small ITAR controlled samples in our office and want to ship them to Pennsylvania, while we do not need a license to ship them domestically, are there any Best Practices when it comes to domestic transport? For example, we are planning to ship via a US flag carrier such as an […]
QUESTION: On marketing materials, how can one tell if a DSP-5 or DSP-73 license will be required? What is considered “technical” data exactly or public versus private? If a demo is not operating, is a license not required? ========== Answers: Is your data “required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance […]
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 […]
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 […]
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 […]
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, […]
