ITAR

ITAR

  • Sub contractor under DARPA BAA

    Question:We just received an RFP from a defense contractor where we would be a sub under their DARPA BAA.  Included is their company’s form specifying that all technical data and computer software generated under this order shall be furnished with unlimited rights as defined in the first two DFARS clauses below.  The third clause below […]

  • Defense Articles subject to jurisdiction by ATF 27 CFR part 447

    I’d like to ask the membership on how they handle the Permanent Importation ofDefense Articles subject to jurisdiction by ATF 27 CFR part 447.If defense item being imported is subject to US Munitions Import List and itsCategory has been “deleted” as inapplicable to imports, thus no Import permitrequired, the question is:  How does the membership […]

  • ITAR

    Question: Hypothetical: US Company A has a wholly-owned foreign UK subsidiary, Company F, that has designed, developed and manufactured a military vehiclecompletely independently of U.S. content, U.S. engineering, U.S. know-howand U.S. parts, manufacturing, etc. Company F wishes to license the vehicleand its technology to Company B located in a different foreign country(Country X) for sales […]

  • How to dispose of scraped ITAR parts

    Question: Can anyone explain the proper way to dispose of scrapped ITAR relatedparts?  Some these parts may be rubber, plastic or even metal. I know that we must keep a record and destroy the parts unusable but, isthere anything in the regulations that specifies how these types of itemsmust be destroyed? I have been told […]

  • DISPOSAL OF ITAR PARTS

    Question: Can anyone explain the proper way to dispose of scrapped ITAR related parts?Some these parts may be rubber, plastic or even metal. I know that we must keep a record and destroy the parts unusable but, isthere anything in the regulations that specifies how these types of itemsmust be destroyed? I have been told […]

  • ITAR 120.22 & 124.C.4.iii

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

  • ITAR RE-EXPORT

    Question: Our sister company in Canada (parent is in the US) has a need totemporary re-export ITAR controlled items imported from the US (under DSP-5).  Temporary re-exports are to both the US, and other foreign destinations. I would appreciate if the members could share procedures they have inplace for such temporary re-exports that summarize tasks […]

  • ITAR licensed routed transaction

    Question:In an ITAR licensed routed transaction, where the USPPI has written permission of the FPPI to file the required AES, is it a requirement to include the freight forwarder in the filing?  Census Regs and help desk says no, this is an optional field, required only when the freight forwarder does the filing.  However, had […]

  • ITAR PARTS LICENSING

    Question:US Exporter A sends ITAR parts to a foreign military jet manufacturer, on a DSP-5.  US Exporters B and C do the same, using their own DSP-5s.  The question is:  if a US party then imports that finished aircraft to the USA, using a BATF permit, is that all that is required?  Meaning, does the […]

  • ITAR RESTRICTED AREA / SIGNAGE

    Question: Do any members with ITAR-restricted locations post signs indicating thatcertain locations are off-limits to non-US citizens?  If so, would youplease share the verbiage used in these signs?

  • Pictures of ITAR Products

    Question: I am looking for a good rule of thumb to follow to determine when a picture of an ITAR item moves from marketing/commercial information to controlled technical data.