QUESTION: My company is subject to both the EAR and the ITAR. I have a question about hiring a person who does not meet the ITAR or EAR definitions of a U.S. person. This is for a U.S.-based engineering position, and the official job description requires access to export controlled technology or technical data. In […]
Question: I’m looking for guidance from the ITAR experts. Our company manufactures plastics and sells them in a raw material form – small pellets that are extruded or injection molded by the customer, or liquids that are also further processed. We are trying to determine if these materials can be considered subject to ITAR. We […]
Question: My company is transitioning to a new ERP system for all of our facilities worldwide –a very small percentage of our US items are still under ITAR control. The server / system admin etc., will not be in the US – does anyone have any experience regarding how to segregate the ITAR items and […]
Question: Does anyone have an ITAR classification procedure they wouldn’t mind sharing? ************ Answers: 22 CFR 121.1(b) – ITAR Order of Review http://pmddtc.state.gov/licensing/dt_OrderofReview.htm ********** Not sure what you are asking for. A couple of things you must do, though, when determining which USML category (if any) applies to an item or product: (1) If you […]
Question: The company I work for was purchased by a Switzerland company a little over a year ago. The owner of the Switzerland company has requested access to our ERP system which includes all drawings and technical data. Upper management has proposal the following: secure our ITAR product is to remove the top level (sellable […]
Question: Can someone explain the definition of “furnishing defense services” under ITAR 122.1? We are U.S. manufacturer and we receive the defense articles from U.S. customers. After we add some value and improve/change the performance of the defense articles received from the U.S. customer, we send back to U.S. customers. For this scenario, do we […]
Question: Licenseable means the NEED to get a LICENSE Exemptions and Exceptions ELIMINATE the need for a LICENSE ******** ITAR 126.5 is the Canadian exemptions section. Most of those are easily “licenseable” (according to at least one version of that definition anyways).  So most likely you meant the 126.1 countries (arms embargoed). But […]
Question: If there are two DoS approved DSP-5 licenses with the same Foreign Consignee, the same exact Defense Article but different End-Users; would there be a violation if the Foreign Consignee sends the serial numbered unit received for End-User A to End-User B and vice versa? Meaning is it okay if they swap the units […]
Question: We are a wire producer, who manufactures wire for many applications. Most of our products are used commercially, but some may find their way into military applications. Everything we make is made to order, meeting specific specs for tensile strength, alloy composition, and of course size. These technically aren’t modified and they are not […]
Question: Would any of the members have an example of an ITAR visitor’s log? Also, does any member can shared a generic or basic training on ITAR to give to our associates? ************ Answers: You might want to look at the attached. If it fits the requirement please feel free to use the form. Visitor Log
Question: Does anyone have a template letter to send to distributors to remind them of US export regulations and restrictions on exporting to sanctioned parties? ========== Addl Answer: I have seen many such letters/ contract provisions and have drafted a few of them myself for clients. Most of the template documents that I have seen […]
Question: We have ITAR controlled engineering drawings saved on a access restricted shared drive on our server (located in the US). When offsite, our Engineers have the ability/authority to VPN in to our system and then access any of their files that are located on the shared drives. None of these files are stored on […]
