ITAR Compliant – What does it mean?

 

More and more companies are requiring that members of their supply chain be ITAR COMPLIANT or ITAR CERTIFIED. Language to that end is often contained in contracts and on purchase orders and Request for Proposals. No where in the International Traffic in Arms Regulations (ITAR) is it spelled out what “ITAR compliant” means.  If you speak to different staff members of the Directorate of Defense Trade Controls (DDTC), you may get slightly different answers, but this “not for attribution” acceptable, generally safe definition of ITAR compliant is as follows:

 

For a company involved in the manufacture, sale or distribution of goods or services covered under the United States Munitions List (USML) or a component supplier to goods covered under USML, the contractual stipulation or requirement of being  “ITAR compliant” means that the company must be registered with the State Department’s DDTC, if required, as spelled out on DDTC’s web site Registration on US State Directorate of Defense Trade Control website and the company must understand and abide by the ITAR as it applies to their USML linked goods or services. The company themselves is certifying that they operate in accordance with the ITAR when they accept being a supplier to the USML prime exporter.

 

In other simpler words, to be ITAR COMPLIANT, a company (USML supplier) needs to register with DDTC and know what is required of them to be in compliance with the ITAR and self certify that they possess this knowledge. This explanation does not constitute legal advice and is not for attribution. If in doubt as to how this concept applies to your company, you should seek legal advice.

 

For more information on online courses covering the International Traffic in Arms Regulations (ITAR), and for classes starting soon, contact an Advisor at (800) 474-8013 or send us an email.

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