ITAR Sign – International Traffic in Arms Regulations notice to visitors
CVG Strategy’s ITAR Sign products help you be compliant with the United States regulations on ITAR and EAR. These controls require US Companies to give notice to visitors, and the CVG Strategy ITAR Sign will give that legal notice that is required.
The Export Administration Regulations (EAR), 15 C.F.R. 730-774, and the International Traffic in Arms Regulations (ITAR), 22 C.F.R. 120-130, govern what technologies may be exported from the United States. The controls are designed to restrict access to “dual use” (i.e., having both commercial and military applications) technology or software to countries or persons that might use such items contrary to the national interests of the United States. The controls are specifically designed to stem the proliferation of nuclear and weapon technologies, and to limit the military and terrorism support capabilities of certain proscribed countries.
In today’s global economy where products are assembled from multiple manufacturers and shipped all over the world, be sure that all your visitors comply with the appropriate aspects of the International Traffic In Arms Regulations (ITAR) and Export Administration Regulations (EAR). Every facility that manufactures or provides services that are classified as restricted on either the United States Munitions List (USML) or Commerce Control List (CCL) must restrict and control access. Giving notice with the display of an ITAR Sign at all facility egress and ingress points enables a company’s reliable regulatory compliance program.
CVG Strategy offers a collection of several types of ITAR Sign products to help you with complying to all appropriate ITAR and EAR controls. By posting an ITAR Sign at entrances, loading docks and internally having an ITAR Sign at departments where restricted work is being performed, a company can use this to give notice to employees and escorted visitors. The ITAR Sign is made from aluminum with a reflective high quality surface, similar to street signs.
Any company who has Registered with the DDTC as an ITAR company, needs to make sure your program includes notice and the use of an ITAR Sign to give notice in accordance with the appropriate ITAR and EAR, U.S. Export Laws and regulatory requirements.
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U.S. Key Export Notice Requirements:
ITAR Signs help you be compliant with the regulations. The US Government requires that all restricted articles (items and technical data) are controlled by the Department of State’s Directorate of Defense Trade Controls (DDTC) via the International Traffic in Arms Regulations (ITAR) 22 CFR Parts 120-130, and cannot be exported from the United States or shared with a Foreign National without prior approval from the United States Government. This applies to articles or services specifically enumerated in the United States Munitions List (USML) 22 CFR Part 121.1. ITAR Signs allow you to give legal notice to visitors on your company property, and to be compliant with US ITAR Regulations.
Restrictions on USML articles:
22 CFR §120.10 Technical data.
(a) Technical data means, for purposes of this subchapter:
(1) Information, other than software as defined in §120.10(a)(4), which is required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance or modification of defense articles. This includes information in the form of blueprints, drawings, photographs, plans, instructions or documentation.
(2) Classified information relating to defense articles and defense services on the U.S. Munitions List and 600-series items controlled by the Commerce Control List;
(3) Information covered by an invention secrecy order; or
(4) Software (see §120.45(f)) directly related to defense articles.
(b) The definition in paragraph (a) of this section does not include information concerning general scientific, mathematical, or engineering principles commonly taught in schools, colleges, and universities, or information in the public domain as defined in §120.11 of this subchapter or telemetry data as defined in note 3 to Category XV(f) of part 121 of this subchapter. It also does not include basic marketing information on function or purpose or general system descriptions of defense articles.
[58 FR 39283, July 22, 1993, as amended at 61 FR 48831, Sept. 17, 1996; 71 FR 20537, Apr. 21, 2006; 78 FR 22754, Apr. 16, 2013; 78 FR 61754, Oct. 3, 2013; 79 FR 61227, Oct. 10, 2014; 79 FR 27185, May 13, 2014]
If your company manufacturers articles or provides defense services that are classified on the USML, you must protect access to your facility and give notice to all visitors as to your company policy. Without giving such notice, if you have a violation, the US Government will visit your facility. Having ITAR Sign “signage” posted giving notice will be physical evidence of an attempt to restrict access, coupled with a strong visitor policy and denied parties screening.
Items / Restricted Articles are controlled by the Department of Commerce, Bureau of Industry and Security Export Administration Regulations (EAR) and the in accordance with 15 CFR Parts 730-774 (Export Administration Regulations). All articles not specifically enumerated in the USML are controlled in the Commerce Control List (CCL). Access to these articles by any foreign country or disclosure of this data to any non-US citizen may be a violation of federal law.
Restrictions on EAR Articles:
Under the “Deemed Export Rule”, there can be an “export” without anything leaving the United States. According to section 734.2(b)(2)(ii) of EAR:
“An export of technology or source code (except encryption source code) is “deemed” to take place when it is released to a foreign national within the United States.”
In turn, under section 734.2(b)(3) of the EAR, technology (including source code) is “released” when it is available to foreign nationals for visual inspection (such as reading technical specifications, plans, blueprints, etc.); when technology is exchanged orally; or when technology is made available by practice of application under the guidance of persons with knowledge of the technology.
If your company manufacturers articles classified on the CCL, you must protect access to your facility and give notice to all visitors as to your company policy. Without giving such notice, if you have a violation, the US Government will visit your facility. Having ITAR Sign “signage” posted giving notice will be physical evidence of an attempt to restrict access, coupled with a strong visitor policy and denied parties screening.