What Does it Mean to be an ITAR Compliant Manufacturer?
If you are in the manufacturing business, then you need to be familiar with ITAR compliance. ITAR stands for the International Traffic in Arms Regulations, and it is a set of regulations put in place by the United States government to control the export of military products and defense-related information.
If your company manufactures any type of product that falls into this category, then you must comply with ITAR.
What is ITAR Compliance?
In the United States, ITAR controls the manufacture, sale, and distribution of defense-related articles. This includes military hardware and space-related items. These are restricted by the United States Munitions List. Companies must follow the regulations, even if they are not involved in manufacturing the products. However, the ITAR registration process does not require any formal quality management system. Instead, it allows the company to be more flexible and meet the requirements of their customers.
Can a Company Be ITAR Certified?
This is a common misconception. You may have heard the term “certified” in relation to ITAR. There is actually no such thing as being ITAR certified. A company is obligated to register as and be compliant with the regulations. A vendor might get a letter asking to certify that their business is ITAR compliant–the real question being asked is “are you registered for ITAR, and do your processes comply with it?”
How Does ITAR Registration Work?
To register for ITAR compliance, you must first complete the registration application form and submit it to the DDTC with all the required supporting documentation. The form is available on the DDTC website, and it will walk you through each step of the process so that there is no confusion. Once you have submitted your application, it will be reviewed by the DDTC to make sure that everything is in order before they approve it. Full instructions and the application for ITAR registration are available on the State Department’s website. Note that a company that is registered with ITAR is not necessarily compliant–that comes next.
What Is Needed For ITAR Compliance?
Once your manufacturing business is registered with the DDTC, you will need to make sure that you are in compliance with all of the regulations. This includes manufacturing your products in a secure facility that is only accessible by authorized personnel. You will also need to have the proper training and procedures in place to protect your manufacturing equipment and manufacturing processes. The government has specified key features of a good ITAR compliance program. Here are some highlights.
- An in-depth organizational policy that includes a description (and flow charts, if appropriate) of the company’s defense trade functions.
- Clear record-keeping, including descriptions of record systems concerning U.S. origin products and procedures for maintaining records relating to U.S. origin products
- Robust internal monitoring, with an emphasis on validation of full export compliance, including adherence to the license and other approval conditions
- An established process to ensure education, training, and provision of guidance to all employees involved in exports
Visit the State Department’s website for more.
Why Is ITAR Compliance Important?
ITAR compliance is not just a legal requirement, it is also a critical part of safeguarding our national security. The United States government takes the export of military weapons and defense-related information very seriously, and manufacturing companies that fail to comply with ITAR could be subject to stiff penalties.
What Happens If You Don’t Comply With ITAR?
If your manufacturing business is not in compliance with ITAR, you could face civil penalties, criminal penalties, or both. Civil penalties can range from fines to revocation of your manufacturing license, while criminal penalties could include jail time and heavy fines.
Vinyl Technology is a leading manufacturer of ITAR compliant products. We’ve been creating products for US government clients, like the Demilitarization Protection Ensemble (DPE), for decades. If you have a project you think would be a good fit for us, get in touch today.