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Posts: 56
Join Date: Feb 2008
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We are a small contract manufacturer of injection molded parts and tooling. A few of our customers produce & export parts with defense applications (for example, electrical connectors and munitions).
We recently learned that if we sell to these customers we should be registered with the DDTC (a branch of the State Department) in order to comply with something called ITAR ( International Traffic in Arms Regulations). We do not do any exporting ourselves, and are having a hard time finding assistance on this topic which is geared toward the small manufacturer with limited legal resources.
One ITAR compliant/ registered customer of ours has told us ITAR compliance can be an extremely complex & expensive undertaking. But there does not appear to be any exemption for small, non-exporting manufacturers—if you manufacture any quantity of parts that are regulated by ITAR, it seems you have to register (with annual fees starting at about $ 2,000) and implement a strict compliance program to avoid severe monetary and even criminal penalties.
Our sense is that many if not most small manufacturers are unaware of this registration requirement. We have also heard that the DDTC now has expanded funding and may be stepping up enforcement on this.
Does any MAPP member have experience with ITAR compliance, or know of seminars or other resources which provide legal or technical guidance, especially for the non-exporting manufacturer?
Any help in this area would be much appreciated.
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