DDTC
Registration:
ITC Strategies assists companies engaged in international trade of
defense articles, technologies and services with registration with the U.S.
Department of State’s, Directorate of Defense Trade Controls (DDTC), and if
necessary the Bureau of Alcohol Tobacco, Firearms and Explosives (ATF).
If any of your manufacturing, export or brokering activities are controlled
by the International Traffic in Arms Regulations (ITAR), then you have a
registration requirement with DDTC. Prior to making an export of
ITAR controlled products/technology, or utilizing an ITAR license exemption,
you must first be registered with DDTC.
Registration is primarily a means to provide the U.S. Government with
necessary information on who is involved in certain manufacturing, exporting
and or brokering activities. Registration does not confer any export rights
or privileges, but is a precondition for the issuance of any license or
other approval for export.
There is a U.S. Government fee associated with Registration. DDTC has
adopted a three-tier registration fee schedule based on certain factors
associated with the registrant. Therefore the fee differs from company to
company.
Manufacturer and/or Exporter
Registration:
- All manufacturers, and/or exporters of defense articles, defense services, or related technical data, as defined on the United States Munitions List (Part 121 of the ITAR), are required to register with DDTC.
- Only U.S. Persons (companies) may
register as a Manufacturer and/or Exporter.
Brokers and Brokering Registration: - All brokers of defense articles, defense services, or related technical data, as defined on the United States Munitions List (Part 121 of the ITAR), are required to register with DDTC. This is a separate registration requirement from the Manufacturer and Exporter registration listed above. In some cases companies that engage in both activities may hold two (2) registrations with DDTC.
- DDTC defines a Broker in the ITAR (part 129) as:
“Any person who acts as an agent for others in negotiating or arranging contracts, purchases, sales or transfers of defense articles or defense services in return for a fee, commission, or other consideration.” 129.2(a). - DDTC further defines a Brokering activity to include:
“The financing, transportation, freight-forwarding, or taking any other action that facilitates the manufacture, export, or import of a defense article or defense service, irrespective origin.” 129.2(b). - Both U.S. and Foreign Persons (companies) may register as a
Broker.
ATF Registration:
Anyone engaged in the business of permanently importing articles on the U.S. Munitions Import List for commercial purposes must register with ATF as an importer under the Arms Export Control Act (AECA) and pay the prescribed fee.
ITC Strategies can guide you through the registration process. From
determining the registration requirements, completing the required
registration forms, determining the associated fees, through submission of
the registration application, ITC Strategies is there with you every step of the way.
