ITAR Registration for Metrology Laboratory?

gary853

Starting to get Involved
#1
We are a ISO 17025:2017 accredited Metrology Lab. We currently do some work for the Areo Space industry. Would it be beneficial to be ITAR
registered?
 
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Jim Wynne

Staff member
Admin
#2
Do you mean ITAF or IATF? If it's the former, I'm not sure any sort of registration is possible. If you meant IATF, registration would be to IATF 16949.
 

gary853

Starting to get Involved
#6
Why would a metrology lab be interested in ITAR?
We have had several potential customers asking if we were ITAR registered. We do inspection work for a couple of aerospace companies. Some of them have asked if we ever considered ITAR registration.
This is why we are investigating how to go about the process.
 

Jim Wynne

Staff member
Admin
#7
We have had several potential customers asking if we were ITAR registered. We do inspection work for a couple of aerospace companies. Some of them have asked if we ever considered ITAR registration.
This is why we are investigating how to go about the process.
Did you ask your potential customers why they would expect a metrology lab to be ITAR registered?
 

Cari Spears

Super Moderator
Staff member
Super Moderator
#8
We have had several potential customers asking if we were ITAR registered. We do inspection work for a couple of aerospace companies. Some of them have asked if we ever considered ITAR registration.
This is why we are investigating how to go about the process.
If your company is inspecting parts for customers that produce defense articles, then they're asking about ITAR because you will be handling their defense articles and their drawings/models. If these customers send you limited dimension drawings that don't state which defense program the parts are for, and if the parts are not identifiable as defense articles, then ITAR registration isn't necessary. However, that doesn't stop some customers from unnecessarily blanket requiring that all suppliers are ITAR registered.

If your company was exporting, then EAR would also apply. If you're inspecting parts and shipping them back to the customer, all within the US, then EAR doesn't apply.

The process is pretty simple - google DDTC ITAR Registration - Article - DDTC Public Portal

It costs a few thousand dollars a year to maintain your registration - it has to be renewed before the expiration date each year. Once you register, if you let it lapse and then years later decide to register again, they will back charge you for all of the years you skipped.
 

Ninja

Looking for Reality
Trusted Information Resource
#9
Cari is on the money... but look also into segregation and separation and access requirements...if even only one of you knows it is for Defense/Arms/Armament covered under ITAR (and you posted, so at least one does) there is typically some infrastructure expense needed for security and access around the articles...
 

Matt's Quality Handle

Involved In Discussions
#10
If your company is inspecting parts for customers that produce defense articles, then they're asking about ITAR because you will be handling their defense articles and their drawings/models. If these customers send you limited dimension drawings that don't state which defense program the parts are for, and if the parts are not identifiable as defense articles, then ITAR registration isn't necessary.

Cari,
Out of curiosity, where does this come from? My company has ITAR stuff, and honestly, I'm not sure anyone there knows what is/isn't ITAR information, nor how to make that determination. I come from a defense background where Classified Information is clearly marked, and there is a literal book on what is/isn't classified.
 
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