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I have a vendor that is doing some dip-coating on a program through one of our higher tier vendors. The higher tier vendor asked if the dip-coating company was ITAR registered and they are not - they are a small job shop. The Prime contract is subject to ITAR but does that mean this 3rd tier vendor needs to be? He's doing standard dip-coating on supplied parts, he isn't making the parts, just dip coating them to specs as provided.