Is your company up-to-date on recent and proposed changes to International Traffic in Arms Regulations (ITAR)?

Government RegulationsThe U.S. State Department recently made changes to the International Traffic in Arms Regulations (ITAR), which govern work with U.S. Munitions List (USML) items that are considered critical to national security. A new exemption to allow the “hand carrying” of ITAR regulated data was announced in the Federal Register on August 27, 2010. This exemption, along with recently proposed exemptions for companies that employ dual- and third-country nationals, will make it easier for companies to comply with ITAR’s administrative burdens. Additional changes recently made to ITAR require all requests to exclude items from the USML to be submitted electronically. The notices of the changes and proposed changes to ITAR can be found here.

The new exemption for the “hand carrying” of technical data outside the United States is expected to benefit many electronics companies. This exemption will allow employees to take laptops out of the country if they contain ITAR regulated information as long as they remain in control and follow the requirements of the Department of Defense National Industrial Security Program Operating Manual.  The full details of the change, effective August 27, 2010, can be viewed here.

Recently proposed changes to ITAR would create a new exemption from “deemed export”  licensing for companies that employ dual- or third-country nationals and meet certain criteria. The current “deemed export” controls within ITAR place an excessive administrative burden on many electronics companies that employ non-U.S. citizens and work with ITAR-controlled items. Regulated intellectual property, such as printed board artwork or technical data, is deemed exported when a non-U.S. citizen has access to this information. The deemed export regulations can apply to the access of common workplace tools such as computer systems storing regulated information. To view IPC’s comments on proposed changes to ITAR regarding dual- and third-country nationals, click here.  

The State Department is expected to propose additional changes intended to simplify ITAR requirements without jeopardizing national security. To learn more about ITAR, U.S. export controls, and IPC efforts, visit:

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