What is ITAR?
The International Traffic in Arms Regulations (ITAR) apply to all US companies that export products and services that fall on the United States Munitions List (USML).
The USML is comprised of defense-related items that require licensing by the US State Department’s Directorate of Defense Trade Controls (DDTC) before these items can be exported from the US. The export of test data associated with items found on the USML is subject to ITAR. For armor testing laboratories in the US, this most frequently applies to rifle-resistant personal and vehicular armor.
Note: Allot appropriate time in your test schedule for DSP-61 and/or DSP-5 licensing approval. Application approval is subject to DDTC’s backlog and staffing constraints. Each may take 2 – 4 weeks.
Who is subject to ITAR?
H.P. White and all other test laboratories within the US must comply with ITAR. Significant penalties are associated with noncompliance.
Which Products and/or Services are Subject to ITAR?
An item’s presence on the United States Munitions List (USML) determines whether or not test data related to the item is subject to ITAR. HP White commonly performs testing on USML items, including:
- Rifle-resistant body armor: NIJ Level III, IV and “Special Type”
- Vehicle armor for military combat vehicles: tanks and armored fighting vehicles
- Vehicle armor for armed vehicles: vehicles with weapons, weapons mountings, or reinforcements for weapons mountings.
How Can I Minimize My Risk of Delays, and Increase my Chances for DDTC Approval?
HP White’s Empowered Official uses the information you provide to file license applications on your behalf with the DDTC. To give yourself the best chance for license approval, and quickest turnaround, provide as much information as possible.
In HP White’s experience, license applications are approved more quickly when clear and detailed explanations and supporting information is provided for Purpose for Testing, Product Description, Market, and the ultimate End-User of the test item is provided.
Please note, without proper licensing, HP White can only provide limited (Pass/Fail) information using an abbreviated test report – typically omitting specifics such as velocity performance information – that contains no detailed sample description. Once licensing is approved by DDTC, HP White is then authorized to release full test data on tested samples.
These DDTC requirements affect all ballistics and ballistics resistance test labs operating in the United States. HP White intends to provide international customers with simple and clear guidelines to getting testing services and test data as quickly and completely as possible, while remaining fully compliant with DDTC requirements.
Once the license application is submitted, HP White has no control over license application processing and approval. Approved license applications typically take about two weeks for approval, but approval can take substantially more time, depending on DDTC’s backlog and DoD staffing.
Are There any Exceptions for Prohibited Countries and Individuals for Getting ITAR Licensing?
Government prohibitions on prohibited countries and persons can prevent HP White from obtaining licenses.
Under some circumstances, licensing to prohibited countries may be approved; such approval is usually in support of projects with US Government entity participation. For example, testing of body armor produced by a manufacturer in Afghanistan for local security forces involved in a project run by the US Military may be granted DDTC approval.
Any test project originating in a proscribed country must have additional levels of documentation to support application. Such documents include Letters of Exemption, contracts with US Government agencies, or documented US Embassy support.
How do I Find the List of Prohibited Countries and Individuals?
Some valuable links are as follows,
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