Do I need ITAR registration to make parts for defense customers?

Start with the activity, not the customer’s logo

A defense customer does not automatically make every commercial part ITAR-controlled, and a domestic job can still involve a defense article or technical data. Ask whether the part or drawing is on the US Munitions List, whether you are manufacturing or furnishing a defense service, whether you will export or temporarily import anything, and whether an exemption applies. The customer’s contract and classification answer those questions; “for the military” is not enough.

DDTC’s registration guidance says registration is generally a precondition to a license or approval, but registration itself grants no export or import rights. Keep registration, classification, license or exemption, US-person access and subcontractor authorization as separate checklist items.

Separate registration from the quote

If classification and authorization are confirmed, price the physical work plus the controls your program requires. An illustrative one-off has $120 material, 1.5 machining hours at $125/hour ($187.50), $60 inspection and $150 controlled-data administration. Internal cost is $517.50. A 20% markup gives $621.00. The $150 is a planning allowance for your own review; it is not a DDTC charge and should be replaced with your actual compliance cost.

Do not add a “registered” badge to a quote as if it promises approval. State the authorization or customer instruction you are relying on, the data covered, the approved outside processes and the quote’s exclusions.

• Handle the marked drawing during estimating

Ask for help where the rule is fact-specific

The ITAR definitions, USML categories and exemptions are fact-dependent. A traditional repair may be treated differently from manufacturing a new defense article; a part’s classification may be controlled by the prime’s technical-data determination. Ask DDTC for an advisory route or use qualified export counsel when the answer affects an authorization. Do not copy a forum answer into a compliance procedure.

If your shop is not ready to control the data and people, decline or return the RFQ without forwarding the files. A decision log that says “classification and authorization not confirmed” is more defensible than an estimate based on an assumption.

• Review email and file-sharing questions

What to do next

Make the RFQ owner record classification, registration status, authorization, people, systems and suppliers before the estimator calculates a price. Revisit the decision when the revision, customer, destination or outside process changes.