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tjsmith57

Commodity Buys & ITAR Restrictions

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I am new to the commodity side of ITAR. Let's say I order HP equipment form a Reseller, other than the ITAR flowdowns what do I need to ensure I cover with my supplier before placing an order?

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In case you still need an answer -

ITAR is only one portion of Export Compliance which is what the DFAR requires in 252.225-7048. Unfortunately, Export Controls apply whether or not you flow down this clause or it's part of your contract.

The main thing to know with Export is that there is a responsibility factor on a company and a personal basis. In other words, you cannot "cover" your supplier. Your supplier has a responsibility to figure out the rules for themselves and put in procedures to cover themselves.

On a one-time basis, a quick way to figure out how to proceed is to contact the manufacturer of the item and ask them for the ECCN or ITAR control number. This will tell you if it's under the jurisdiction of the Commerce Department or the State Department. Just because something is going to the military doesn't mean it's ITAR, it could be EAR. ITAR doesn't regulate most things.

Once you get the ECCN or the ITAR number you'll have an easier time googling the rules for the particular item category. If there are NO exports because everyone involved is american then fill out, sign, and return an End-User statement telling them who the customer is and what the use will be.

You should get training to figure out what constitutes an "export" and the many many many nuances of Exports Compliance.

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