Question: Hello, Details: I am new to an organization that has an open DSP-5 License, I don’t know what details were submitted 2 years back when the license was requested, but it covers two line items: 1 – the commodity with a quantity of 3,000 and 2 – Technical Data: Quality assurance test data with […]
Question: We all understand that if you make a design change to an EAR controlled part for a military end use that it will likely be caught in “specially designed” and controlled under 600 series or move directly to ITAR. Is there ever a circumstance when the reverse could be true? For example, a component […]
Question: We have a product that we build in the UK and falls under UK dual use controls, it ships from the UK under a UK OGEL Under the US controls, this item is an ITAR product. For this reason, we don’t sell the product to the US market because it makes returns and product […]
Question: Greetings members. In this scenario: A foreign subsidiary of a US parent company intends to manufacture defense related parts for a foreign customer. The foreign subsidiary and foreign customer are located in the EU and within the same country (just as a note). Can anyone shed light on what the ITAR implications would be […]
Question: Hi, I’m in the process of adding export training to my existing base of import knowledge to round out my resume. I’d like input regarding any trainings/certifications that would be most relevant and impactful when seen by future employers. Does anyone with an export background have suggestions? Answer 1: Hi there. Content Enablers offers certification […]
Question: Hello – I’m curious how others interpret the verbiage in USML category XI(c)(1). This USML category controls the following: Application Specific Integrated Circuits programmed for defense articles in this subchapter. When referring to subchapter, does this include other defense articles listed in different USML categories (e.g., USML category IV, XII, XX, etc.) are specifically […]
Question: This may be a newbie question and I am not a newbie but I have not come across this question nor ever had to use an ITAR exemption as we mostly fall under Commerce Dept. classifications: 126.5 – can be used to exempt from need for DSP-5? Cat. III hardware, not SME. I am […]
Question: Is my understanding accurate that 126.5(b) Canadian exemptions allows for unclassified defense article (non-SME) exports from US to a Canadian registered person (company) without the usual State/DDTC export license? The items fall under Category III and are not SME. We have reviewed the 120.15, 120.16, 120.17, 123.22, and 126.1 referenced within § 126.5 . […]
Question: Hello – We would like to confirm if a DSP-5 technical data license is acceptable to exchange build-to-print technology only to a foreign consignee to assemble hardware or if a TAA is required? No defense services will be performed, only build-to-print technology will be shared (no design/development data). Thank you. Answer 1: This scenario […]
Question: We shipped a UAS unit under a DSP-83, this unit cannot be retrieved and has been considered a total loss, the initial voluntary disclosure has been filed, I am now working on the final disclosure and corrective actions. Can our wonderful panel confirm that 1. A DSP-74 will be needed to reconcile the DSP-73 […]
Question: Hello ICPA Members, We utilize the Canadian exemption under the ITAR – 22 CFR 126.5(b) to export defense articles temporarily to Canada and to permanently export technical data to Canada. We are reading Supplement No. 1 to Part 126, Note 14 and see that a semi-annual report must be provided to DDTC. Our questions […]
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 […]
