Who Must Register
All manufacturers, exporters, and brokers of defense articles, related technical data and defense services as defined
United States Munitions List (Part 121 of the ITAR) (PDF, 7MB) are required to register with the Directorate of Defense
Trade Controls (DDTC). Registration is primarily a means to provide the U.S. Government with necessary information on who is
involved in certain manufacturing, exporting and brokering activities. Receipt of ITAR §123.9 retransfer authorization does not confer any export rights or privileges, but is a precondition for the issuance of any license or other approval for export.
- Per ITAR §122.1, any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with DDTC. Manufacturers who do not engage in exporting must nevertheless register.
- Note: U.S. Distributors and other U.S. persons exporting parts and components and other defense articles and services outside of the United States are considered to be exporters. U.S. and Foreign (i.e., non-U.S.) Distributors and other U.S. and non-U.S. persons that broker defense articles or defense services must register as a broker.
- Per ITAR §129.3, any U.S. person, wherever located, and any foreign person located in the United States or otherwise subject to the jurisdiction of the United States (notwithstanding ITAR §120.1(c)) who engages in the business of brokering activities with respect to the manufacture, export, import, or transfer of any defense article or defense service subject to the controls of ITAR §121 or any “foreign defense article or defense service” (as defined in §129.2) is required to register with DDTC.
- Note: Brokers may not obtain export licenses. U.S. Brokers that need to obtain export licenses must also submit a separate registration as an exporter.
3. Foreign Military Sales (FMS) Freight Forwarders
- Per ITAR §126.6(c)(6)(i), a U.S. freight forwarder under the Foreign Military Sales (FMS) program must register with DDTC as an exporter. The applicable embassy must designate a registered U.S. freight forwarder for their FMS transactions by sending a letter on embassy letterhead signed by a senior embassy official to the Office of Defense Trade Controls Compliance. If the designated U.S. freight forwarder is not the U.S. registrant but rather a U.S. affiliate listed in the registration, then the embassy must specify the designated U.S. freight forwarder and include “an affiliate of (insert U.S. registrant legal name)”.