Export controls and the International Traffic in Arms Regulations (ITAR) have hit the big leagues. Even NPR’s Martin Kaste is covering it! I think such coverage is great because outside of the University research communities not everyone has gotten the memo.
Just because a product can be used on a commercial item doesn’t mean it isn’t controlled for export. You have to run through a series of questions to determine the answer.
Information you need:
- End use
- End User
- Where it is going
- Technical specifications
- Design process
Then you perform the catch and release analysis. If you are grabbing a copy of ITAR or Googling it. BE CAREFUL. You must get an up to date copy and the government links are not all up to date. Recent ITAR changes took place in January so you need a post January 2014 copy of the regulations. For more information on the new catch and release process to determine if a product is controlled see our article on ECR… or our blog on classification and catch and release?? Bottom line. You need to do your homework and train your company to avoid inadvertent error.