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Export/JCP Etc


paris_tj

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I am new to all this and have a newb question.  I apologize now.

How does a small business deal with the Export control laws/JCP and etc.

Say I have a part I mfg for the government and I need to send it out to be painted and they need the drawings and specs. How does this play into the JCP/Export laws? I have read docs and etc and honestly, I am more confused now then before I started.

Any guidance is appreciated before I do something wrong.

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  • 2 months later...

Hi, I'm with a small business firm. First, we register annually with the JCP. This is typically the first step required to gain access to Govt. export controlled data. As far as actually manufacturing items and complying with any applicable EAR/ITAR regulations that apply to the items - we make sure all our drawings are marked with the appropriate export warnings. We counsel our fabrication vendors on export law, which requires that they may not provide the drawing or allow the part to be made/accessed by any foreign nationals. The electronic copies of the drawings in their system must also not be accessible to foreign nationals. It is on our drawings and export restrictions are notated on any fabrication POs we send to vendors when it is applicable. We also talk to them and make them certify with signature that they understand and will abide by the restrictions which includes not allowing access of the information to any foreign nationals. For extra good measure, our non-disclosure agreements that include export control compliance provisions. 

Was the drawing you received of the part from the Govt. marked as an export controlled item? Sometimes larger assemblies are export controlled as a whole, but the smaller components individually are not - like the fasteners, individual fabricated sheet metal pieces like brackets etc. are not on their own export controlled. So, by segregating the larger assembly drawings showing the whole widget and how it goes all together, we can avoid some export restrictions just by sharing very limited part information and using a number of vendors. We also go out of our way to find/use vendors who can outwardly certify that they are ITAR compliant. 

This is just an example of how we address compliance, by not knowing about your part or your selected vendor, or your contract requirements regarding data handling, the above may not apply to your situation at all. The DDTC is another good resource to give you clarification on your specific situation/item. 

https://www.pmddtc.state.gov/?id=ddtc_public_portal_contact_us

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There are consultants who specialize in this area. A google search might lead you to one in your local area. Suggest you pay a bit in return for peace of mind.

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  • 1 month later...
On 1/31/2019 at 12:11 PM, paris_tj said:

I am new to all this and have a newb question.  I apologize now.

How does a small business deal with the Export control laws/JCP and etc.

Say I have a part I mfg for the government and I need to send it out to be painted and they need the drawings and specs. How does this play into the JCP/Export laws? I have read docs and etc and honestly, I am more confused now then before I started.

Any guidance is appreciated before I do something wrong.

A side question for you.... how long did it take you to get approved with the JCO?  I was approved after some months of waiting... but came to find out I need additional permissions/coordination to access cfolders drawings.  It's been just a very long and arduous process.

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