Question:In 2006 we received a license for the an ITAR controlled item we purchased from a vendor. The vendor has since obtained a favorable ruling on their CJ putting the items under Commerce jurisdiction under eccn 3A001e.4 Our foreign office needs to return one of the items approved under the license we obtained in 2006 […]
Question: It seems that over recent years I have seen a few government prosecution cases regarding the comparatively specific regulatory definition of Public Domain in the ITAR (as opposed to a somewhat broader defn under EAR for ‘publically available’, for example). But I am not a lawyer, and don’t have access to those jungle drum […]
Question: Question: how is foreign origin defense/military technical data & hardwaretreated for ITAR purposes? The definitions of “defense article”& “technical data” in 120.6 & 120.10 do not specify that the items mustbe “US origin”. But certainly foreign person designed foreign origin data &parts sitting in a foreign country is not subject to ITAR. So I’m […]
Question:Need guidance on scrapping/disposing of ITAR hardware. Does anyone have a procedure or guidance from DDTC? 1) Scrapping within the U.S. – I assume that building into your contracts with the scrap yard, trucker etc. that only U.S. citizens are employed, no issue here. 2) Scrapping/disposal OUTSIDE the U.S. – U.S. export was made legally […]
Question: We have learned that several CBP ports have issued public bulletins orpipelines giving the policy on processing entries with ITAR exemptions. Wehave the public bulletins from CBP in Chicago and Buffalo. Do any other CBPbulletins or pipelines exist on this issue
Question: Does it seem plausible that an EEPROM would fall under USML XI(c)??: “Components, parts, accessories, attachments, and associatedequipment specifically designed or modified for use with the equipmentin paragraphs (a) and (b) of this category, except for such items as arein normal commercial use” Our vendor is saying their low cost EEPROM fall here b/c […]
Question:Can any of the ITAR experts in the membership advise what the expression “ITAR cleared” means?
Question:Hi ICPA people…could you please forward this easy peasy question to the membership? Thanks a bunch ITAR Part 120.10 states, when defining ‘technical data’, that is is Information, other than software as defined in Sec. 120.10(4), which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance or modification of defense articles. […]
Question:Does anyone have a basic procedures template for ITAR that they might be willing to share? I have been tasked with developing basic “guidelines” and procedures for handling ITAR product, and was hoping not to completely start from scratch. *********************************************************************Answers:The NASA Export Processing Template is pretty basic. URL is: http://www.hq.nasa.gov/office/oer/nasaecp/eptannx.html You’ll have to tune it […]
Question: We have restricted areas that contain ITAR related products and require swipe badge to gain access. We have visitors come to our plant and the question is: What type of documentation you have your visitors show in order for them to gain access to ITAR restricted areas?
Question: We are trying to standardize our process with in regard to the importing goods controlled under USML vs commercial. Currently we check each shipment, through various automated systems, at the time of import to see if an ITAR exemption or licenses apply. If we can ensure that this information appears on the commercial […]
Question: We are a domestic manufacturer of a safety sensor (light curtain), which we have offered to a US defense contract manufacturer. It will be used in a door closure for an armored vehicle, to keep fingers from getting pinched. The US defense contractor is requiring us to be registered with ITAR. Does this sound […]
