QUESTION: We make cables assemblies for various types of equipment. We use commercial available cable and connectors and then we will cut the cable and attach the connector as specified by the customer. Some of these are for commercial use, some go into spacecraft and some go into military equipment. We are challenged with the classification of the […]
QUESTION: If you manufacture an item that is a “specially designed” “part” controlled under the ITAR, and that item is unintentionally manufactured out of spec, is it no longer “specially designed” and controlled by the ITAR because it is out of spec? %%%%%%%%%% ANSWERS: Does the out of out of spec item meet the ITAR […]
QUESTION: We do not produce ITAR controlled items but have been contracted to perform testing at our customer facility that has ITAR controlled technology Do we need to come up with a Technology Control Plan for our engineer or is this normally completed by the ITAR facility? ************ Answers: Long as the employees assigned to […]
QUESTION: My company does not normally deal with ITAR issues so looking for some guidance from the community. We have been contracted by a government agency to test components controlled under the ITAR and will send one of our engineers to the customer site to perform the training. We are being asked to complete the […]
QUESTION: For those who have been contacted by “one of the big couriers” (to remain un-named) US customs brokerage, about ITAR violations they created on your import declarations for temporary import license exemptions (22 CFR 123.4), how are you handling the situation? =========== Answers: We filed disclosures with both CBP and DDTC. =========== Hi, There […]
QUESTION: An ITAR part is imported into the US, under 22 CFR123.4(a)(1), and the exemption is properly claimed. The part is temporarily exported to Canada for repair (no upgrades), under 22 CFR 126.5(b), and return to the US for shipment back to the owner, closing the 22 CFR 123.4(a)(1) importation loop. Is there an exemption […]
Question: I am preparing a voluntary disclosure for an ITAR part that shipped accidently, as there was no hint from any of the parties involved or the description of the goods that this defense article was indeed an ITAR part. So, my question is how do I go about revising the EEI? Is my only […]
QUESTION: I was very surprised to learn that on the new DECCS (ITAR) licensing application, a user cannot be both a Drafter and an Empowered Official. I confirmed this with DDTC although there is no regulatory basis for this limitation. In our organization, we have well-qualified individuals who are appointed Empowered Officials overseeing multiple locations […]
QUESTION: Is anyone else seeing this requirement in their 2020 ITAR renewal registration letter? We also require that you provide information on how you ensure that foreign persons will not have access to defense articles without written authorization from the Directorate of Defense Trade Controls, as required by ITAR Part 123, within 30 days to […]
QUESTION: I am now the EO for a company and have been here approx. 6 months. In reviewing ITAR compliance, I discovered that we are not registered. I am trying to determine whether I simply need to re-register the business or if we have a larger issue. We make products covered by ITAR but have […]
QUESTION: I am now the EO for a company and have been here approx. 6 months. In reviewing ITAR compliance, I discovered that we are not registered. I am trying to determine whether I simply need to re-register the business or if we have a larger issue. We make products covered by ITAR but have […]
QUESTION: Our facility produces both ITAR and 600 Series controlled product. The IT group would like to hire a Canadian/Great Britain citizen to work on the MRP system. Would a license from both State and Commerce Departments be required? ============ Answer: If they have access to the 600 series and ITAR data then of course […]
