Question: I have a question related to ITAR registration. I am doing the ITAR registration, form DS2032 for the mother company (corporate headquarter), I was wondering do our subsidiaries have to submit their own applications also? *************** ANSWERS: DDTC requires that subsidiaries be included under the corporate registration. Each subsidiary may wish to have a […]
Question: Would anyone be willing to share a copy of an ITAR internal training presentation? *********** Answers: As a result of Export Controls Reform, much of this has been/will be changing. Might be best to wait until all the dust settles. Right now, the USML is a hybrid of legacy application design vs. a positive […]
Question: One of our US research facilities has some ITAR items on site that they use for testing. They will soon be finished with the testing and want to get rid of the items. What are our options? Can we dispose of the items? If so, what is the recommended method? Can we send back […]
We have a supplier that manufacturers Solder Stencils for ITAR circuit card production. Is this supplier required to be registered with DDTC? ANSWERS: Yes. They should register with DDTC. ************* Remember, “use” should not be considered when classifying product under the ITAR. The question you need to ask is; was the […]
Our products transitioned from ITAR to EAR regulations in January. The goods now have a 600 series ECCN and is controlled for RS, UN and AT. Can we display the goods at domestic trade shows? The demo our marketing team is working on will show a cutaway (technical data). Do we need to […]
QUESTION: Question: I have an ITAR unclassified article to be returned for software upgrade. Does software upgrade constitute an upgrade whereas we would use exemption 123.4(b) or can we use 123.4(a)? The general consensus here is that if the upgrade does not change the basic performance of the item then 123.4(a) would […]
QUESTION: My company builds Category IV ITAR boards. We a looking at suppliers to create special shipping boxes to ship our boards safely and reduce damage. A new packaging company is requesting that we send them pictures of the board, diagrams, and dimensions so they can create a box specifically designed for these […]
Question: Our company’s products have, until now, been controlled solely by the EAR. But it looks like we will be dipping our toes into the ITAR puddle soon. Although I have worked for companies subject to ITAR, I have never prepared a company from scratch for ITAR activity. I want to make sure I am […]
Question: I have the need to get technical data enclosed on hard drives from US to Bahrain. Unfortunately, there is no time to submit licensing for foreign consignee. Under ITAR exemption 125.4(b)(9) we can have an employee(US Person) hand carry product directly OR ship directly to the US Person(employee). The Hand carry is pretty clear, […]
Question: We sell the ITAR controlled items to US domestic customer (A). Our US domestic customer (A) sells and exports the ITAR controlled items to their oversea customer (B). It’s a domestic sale for us. We would like to know if foreign customer B can come to our plant and do the source inspection at […]
Question: Here is a question about ITAR brokering that I am putting out to the membership’s ITAR experts and attorneys. Company A is a registered ITAR exporter, Company C is a foreign logistics company that sells to a foreign military government, Company B is a foreign company that coordinates the shipment between Companies A […]
Here is a question about ITAR brokering that I am putting out to the membership’s ITAR experts and attorneys. Company A is a registered ITAR exporter, Company C is a foreign logistics company that sells to a foreign military government, Company B is a foreign company that coordinates the shipment between Companies A and […]
