ITAR flow down to Processors (Outsourced Processes)

J Allen

Involved In Discussions
#1
The US Department of State website (US State Department - Policy - Directorate of Defense Trade Controls) defines “ Who Must Register” for the DDTC. It states:

"All manufacturers, exporters, and brokers of defense articles."

Are process houses who perform plating, Material/Tensile/Mechanical testing, Chemical Analysis, ...etc required to be ITAR registered based on the statement above?

They do not manufacture or export.

I really need clarification.
 
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Ninja

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#2
Hi J Allen,

I would ask that of your compliance agent/customer, not a public forum.
Answers from this forum won't give you much of a defense if the decision is questioned later...certainly not in the realm of ITAR.
 
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