ITAR (International Traffic in Arms Regulations) - Export control procedure.

S

Srinugurrala

#1
Hi all,

Can any one help me out in getting Export control procedure in ITAR(International Traffic in Arms Regulations).

Thanks in adavance.
 
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#4
Thanks Wit

I need some information on Export control procedure.
You should familiarize yourself with the regulation. If you are making products that fall under ITAR, you "must" be familiar with the complete regulation.

Your question is still vague. ITAR is a complex regulation and violations have severe penalties, including jail time.
 

thelastdon99

Starting to get Involved
#5
I hope someone can help me answer this question. I work for a company which currently manufactures medical devices and i am fairly familiar with navigating CFR's. We are considering opening up our business to manufacture prototypes and other components from defense contractors.

We would not be involved with the export or sale of products, we would only act in the capacity as a "contract manufacturer". To what extent does ITAR apply to us?

Basically we will get blueprints to manufacture something and we wont know if it's going in a dishwasher, or a missile, so what if anything do we have to do to be compliant?

Thanks!
Dan
 

Al Rosen

Staff member
Super Moderator
#6
I hope someone can help me answer this question. I work for a company which currently manufactures medical devices and i am fairly familiar with navigating CFR's. We are considering opening up our business to manufacture prototypes and other components from defense contractors.

We would not be involved with the export or sale of products, we would only act in the capacity as a "contract manufacturer". To what extent does ITAR apply to us?

Basically we will get blueprints to manufacture something and we wont know if it's going in a dishwasher, or a missile, so what if anything do we have to do to be compliant?

Thanks!
Dan
It doesn't matter what it's going into, if the technology falls under the ITAR regulation and it's going into a dishwasher, you will be restricted to whom you may export the dishwasher to.
 

thelastdon99

Starting to get Involved
#7
Al,
I appreciate the quick response, but i need some further guidance. I understand that if the item is an ITAR regulated device or component that it needs to follow regulations, what i dont understand is how my company follow's ITAR regulations for a product which we dont know what the end use will be?

If we are given blueprints to create a "widget" and we create it per spec, sell it to the US defense company only and don't directly export it are we regulated? We will not be exporting anything. Your insight is greatly appreciated!

In essence are we responsible for asking the customer if the component is being made for an ITAR regulated device, or should we stay "in the dark".
-Dan
 

Al Rosen

Staff member
Super Moderator
#8
Al,
I appreciate the quick response, but i need some further guidance. I understand that if the item is an ITAR regulated device or component that it needs to follow regulations, what i dont understand is how my company follow's ITAR regulations for a product which we dont know what the end use will be?

If we are given blueprints to create a "widget" and we create it per spec, sell it to the US defense company only and don't directly export it are we regulated? We will not be exporting anything. Your insight is greatly appreciated!

In essence are we responsible for asking the customer if the component is being made for an ITAR regulated device, or should we stay "in the dark".
-Dan
I'm not an expert, but you must exercise due diligence. If you "stay in the dark", then you would be in violation. My advice to you is attend an ITAR training seminar or find someone who is an expert.
 
S

Sorin

#9
Al,
I appreciate the quick response, but i need some further guidance. I understand that if the item is an ITAR regulated device or component that it needs to follow regulations, what i dont understand is how my company follow's ITAR regulations for a product which we dont know what the end use will be?

If we are given blueprints to create a "widget" and we create it per spec, sell it to the US defense company only and don't directly export it are we regulated? We will not be exporting anything. Your insight is greatly appreciated!

In essence are we responsible for asking the customer if the component is being made for an ITAR regulated device, or should we stay "in the dark".
-Dan
That's a violation right there...just to give you an example of how wide it goes: assume your company is working on ITAR items and you are to go to visit the customer for a technical meeting. You must take the plane. During the flight you open your laptop/notebook and consult technical specs of the item(s) in question (could be text only). This is a violation because you have no control over who might see the info.

I'll suggest a webinar from NADCAP (it's only 39 $, you get the slides after the presentation). See "ITAR / EAR and the Nadcap Audit" at this link:

http://www.equalearn.com/learncente...-BCF917C0-0D8F-4B31-8285-5A8AF16DDBF7&page=32

Even if it's NADCAP related, it's still a very good introduction to ITAR (and quite cheap, you can hook-up the laptop to a projector and have as many ppl as you wish to assist).
 
Z

z28tt

#10
If we are given blueprints to create a "widget" and we create it per spec, sell it to the US defense company only and don't directly export it are we regulated? We will not be exporting anything. Your insight is greatly appreciated!

ITAR 122.1 (a) states that manufacturers of defense articles must register, even if you don't export. There are exceptions, like university research...

http://pmddtc.state.gov/regulations_laws/documents/official_itar/2012/ITAR_Part_122.pdf

? 122.1 Registration requirements.​
(a) Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with the Directorate of Defense Trade Controls. For the purpose of this subchapter, engaging in the business of manufacturing or exporting defense articles or furnishing defense services requires only one occasion of manufacturing or exporting a defense article or furnishing a defense service. Manufacturers who do not engage in exporting must nevertheless register.
 
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