Government Relations, LLC has 25 years of experience registering companies with the Directorate of Defense Trade Controls (DDTC) as a prerequisite for International Traffic in Arms Regulations(ITAR) compliance. We will register your company with the DDTC for a flat fee. Your company is free to register with the DDTC directly, and may consider that its best option. Unlike Commodity Jurisdictions, setting up an Export Management System (EMS), or submitting an ITAR voluntary disclosure, the consequences of a poorly planned strategy or improperly submitted paperwork are relatively minor. The most common complaint is that the application is time-consuming and/or tedious to complete. After hours of work, the DDTC may send the registration application back to your company with a “returned without action (RWA)” and an inscrutable citation to conform to some bureaucratic regulation. As long as your company has someone with the patience and planning to get the registration approved or renewed before it expires and before you need an export license, you will not likely suffer major consequences.
However, you are probably running your business to make money and not reading through the International Traffic in Arms Regulations (ITAR) and guidelines. If you want to save yourself the hassle, you can have us do this work for you while you focus on what you do best – your business.
Even if your company chooses to register with the DDTC directly, we are available to guide your company along the process. Below are some frequently asked questions (FAQ) to help your company with the process:
What if the Export Control Reform (ECR) moved the article my company exports and/or manufactures from the USML to the Export Administration Regulations (EAR) 500 Series or 600 Series? You can de-register with the DDTC and save yourself both time and money. You will still be required to obtain an export license, but from the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce instead of DDTC at the State Department. Export licenses for EAR 500 Series and EAR 600 Series items are generally easier to obtain than ITAR USML articles.
Who must register with the DDTC?
All manufacturers, exporters, and brokers of defense articles, data, and services as found on the United States Munitions List (USML) (Part 121 of ITAR) are required to register with the DDTC. The registration is a prerequisite to export, but does not allow export which is usually done through an export license.
Does a manufacturer have to register with the DDTC even if they do not export?
Yes, manufacturers of items on the USML must register whether or not they export (ITAR 122.1).
I am an exporter or distributor of a component, service, or part of an item on the USML, do I have to register with the DDTC? Yes, even if you only distribute a part of an USML article or service, you must register with the DDTC.
What must I do to register with the DDTC? You need to complete a form DS-2032 and submit it electronically along with all necessary documentation and attachments. Instructions are on the DDTC website. http://www.pmddtc.state.gov/registration/crp.html Please ignore the guidelines for the paper submission which are still posted on the DDTC site as of mid 2014. Paper submissions have not been accepted since January 1, 2014 as our experience and the DDTC’s own website confirms on another location. http://www.pmddtc.state.gov/registration/faqs_reg.html#1
How much does DDTC registration cost? Initial cost is based on a three-tier system, as of 2014, the cost for new registrations are between $2,250 to $2,750 payable directly to the U.S. Department of State. For registration renewals there can be additional costs based on the number of license applications submitted during the previous registration period. See the DDTC for details. http://www.pmddtc.state.gov/registration/faqs_reg.html#4
Why is your flat fee a $1,000? The U.S. Department of State expects consultants such as Government Relations, LLC to work with the companies that they help register by doing training, helping develop an Export Compliance Management System, and guide a company through the critical initial regulatory period. Additionally, many companies fail to provide required documentation such as the Electronic Payment Confirmation from their bank or financial institution plus the Trace/IMAD number. Assuming that all paperwork is provided by you we escrow up to $300 for the State Department expected assistance to your company.
Do I have to do anything? We will need information from your company, such as who is on the Board of Directors, what products you sell, etc., but otherwise we take care of the actual paperwork and “walk” your papers through the DDTC registration process.