The Directorate of Defense Trade Controls (DDTC) cannot provide a definitive answer without undertaking a Commodity Jurisdiction (CJ) review of your item and making an official CJ determination. However, most manufacturers are able to self-classify their items by reviewing International Traffic in Arms Regulations (ITAR) §§120.2, 120.3, and 120.4 (which relate to the CJ process) and ITAR §121.1 (the U.S. Munitions List or USML). It is important to review all of these sections since some items that could be considered civil (e.g., hunting rifles and commercial satellites) are captured on the USML for export purposes. If, after reviewing the pertinent sections of the ITAR, you still are not sure if your item is controlled on the USML, then submit a CJ request. Guidelines for submitting the CJ request can be found online at Commodity Jurisdiction Page.
Does our company need to register prior to the submission of a CJ request?
Registration with DDTC is NOT required prior to submission of a CJ request.
We prefer that the manufacturer submit the request because of the background and sales information required. However, a designated representative may submit a CJ request on the manufacturer's behalf. In such cases, the CJ request package must include a letter of authorization from the manufacturer on company letterhead signed by a company official, a mailing address, and phone number.
You do not need an export license from DDTC if your item is not controlled on the USML. That remains true even if you are selling the item to a foreign military. The end-user does not determine export jurisdiction.
How long does it take to get a CJ determination?
It varies depending on the complexity of the request and the recommendations of the reviewing agencies. Our goal is to complete CJ requests in 60 days. However, for the first six months of 2007, median processing time of completed Commodity Jurisdiction determinations was 106 days.
Has there been a change regarding export jurisdiction for L-100/C-130 spare parts?
Please go to Air Craft Parts Page for an announcement on this subject. Included on this page is the relevant Federal Register notice and common Q's and A's on the topic.