ITAR

ITAR

  • Audits – ITAR

      Question:   Auditors  (internal /external) asks us to provide them with different types of documents for audit purposes, such as Purchase Orders, Request for Quotes, analysis reports, performance analysis, etc. However,  some of these documents might have ITAR-controlled information. In addition, the auditors might  or might not be US persons.  Can anyone  share, provide  […]

  • QUESTION ON ITAR DOMESTIC IMPACT

      Question: Does anyone have a briefing or presentation for senior leadership on how ITAR affects domestic commerce?  I have an executive leadership team that strongly believes the ITAR only applies to physical exports.   

  • Aircraft engine jurisdiction (addtl answers)

      Question:   When it comes to aircraft engines there are only a few large OEMS – GE, Pratt Whitney and Rolls Royce.  Is it safe to say then that any aircraft engine made by the US OEMs GE & Pratt (or consortia that they belong to…CFM, IAE) are subject to US export regulation..EAR or […]

  • Aircraft engine jurisdiction

      Question:   When it comes to aircraft engines there are only a few large OEMS – GE, Pratt Whitney and Rolls Royce.  Is it safe to say then that any aircraft engine made by the US OEMs GE & Pratt (or consortia that they belong to…CFM, IAE) are subject to US export regulation..EAR or […]

  • CCL/USML changes

      Question: Is there a time frame attached to when the proposed changes to the CCL/USML will actually take place? ************

  • Items with both ITAR and ECCN designations

    Question: I have heard in the past that an item can have both an ITAR designation and an ECCN designation – but that when this occurs, ITAR trumps EAR. The license would have to go through State. Is it correct that an item that is ITAR can also have an ECCN number, assuming that most […]

  • DDTC debarment and big name forwarders

    Question: The recent debarments by DDTC of certain big name forwarders apply only to the listed locations. Are any other companies having internal dialogs about making business decisions not to use other locations of the forwarder (i.e. if only the Albanian location was debarred, are you considering not using their locations in Estonia also?). I […]

  • Impeller and ITAR

    Question: I have a impeller and I need to to know if it is subject to ITAR. I verify the information in 121 Munition list but it only states propellers. *************

  • Canadian item for repair and export

    Question: We have a customer in the Middle East that is requesting to send a part to the US for repair. The part is manufactured in Canada and is controlled as ECL2-10 under Canadian Law. I have been instructed that this part would fall under the ITAR for the export back to the customer, we […]

  • DSP-5, TAAs, and MLAs in offshore procurements.

    Question:Looking for clarification of the interplay between DSP-5, TAAs, and MLAs in offshore procurements. ITAR 124.13 provides good guidelines for licensing of offshore procurements via a DSP-5.   Pretty much the technical data being is just that data that is required for bid purposes for hardware that is “build-to-print”. In some cases additional information (not […]

  • Begin handling ITAR goods

    Question:Can any of the membership please advise process to begin handling Classified ITAR regulated goods.  How long does this take and how involved?

  • Manufacturing information on a TAA

    Question:For the ITAR experts:  The 120.21 definition of an MLA is “..an authorization to manufacture defense articles abroad”.  So they key difference between TAA and MLA seems to be the granting of manufacturing rights to a foreign party as opposed to NOT granting manufacturing rights. So if I need to send manufacturing information (technical data) […]