Perhaps the name sounds intimidating, or maybe it is the idea of signing up for government regulation that scares some businesses away from registration under the International Traffic in Arms Regulations (ITAR). Regardless of the reason, if you are a business that manufactures, exports defense articles, or furnishes defense services then you are required to be registered.
That said, what is ITAR? ITAR is the International Traffic in Arms Regulations, and manages military specific products / end use. The legislation seeks to control access to specific types of technology and associated data, and to prevent the disclosure or transfer of sensitive information regarding military applications. The Directorate of Defense Trade Controls (DDTC) at the State Department oversees ITAR registration under ITAR Part 122.
Are you still with me? In the case that you are, a defense article is defined as a part, article, service, and related technical data that is listed on the U.S. Munitions List (USML) per 22 CFR §121.1.
If you take the time to look through 22 CFR §121.1 you might see some buzz words such as flame throwers; torpedoes; combat shotguns; and machine guns, and think to yourself, “what does that have to do with our product?” If your company is required to be ITAR registered then chances are likely your product / service is being used in a defense article of some type.
Who can be involved in an International Traffic in Arms Regulations project?
You must be a U.S. Persons to be involved in an ITAR project. What is a “U.S. Persons?” A U.S. Persons is a U.S. Citizen; a permanent resident of the U.S.; or corporation, business, or organization that is incorporated to do business in the U.S. by law. There are also specials licenses that can be received to allow others access to ITAR controlled information, but we will not be discussing those here.
Samtec uses secure internal systems for all ITAR projects to ensure that all documentation including drawings, B.OM.s, work instructions, routing slips, etc are accessible to only U.S. Persons.
How does Samtec address ITAR products?
A majority of the products that Samtec sells are considered to be Commercial off-the-shelf (COTS), and as such do not fall subject to ITAR compliance. A COTS part is a part that is sold in the commercial marketplace, and can be used in a variety of applications; including military / aerospace applications.
In the case of a modified COTS part or a true custom part, Samtec is capable of providing a part that is compliant with ITAR and is well positioned to support the challenging high tech needs of the military, security, and aerospace industries.
Some of the information in this blog was taken from the Samtec ITAR Registration Compliance Flyer, and it can be located here. You may also request a copy of Samtec’s ITAR registration approval letter (registrant code redacted), by emailing CSG@Samtec.com.
If compliance is a topic that interests you, make sure to check out the related posts below, and all of Samtec’s information here.