May

19

First Reggie Award Goes to Prototron Circuits


Posted by at 5:18 pm on May 19, 2010
Category: DDTC

Reggie Award StatuetteRegular readers know that an on-going feature involves examining press releases issued by companies after they have registered their company with the Directorate of Defense Trade Controls (“DDTC”) as required under Part 122 of the International Traffic in Arms Regulations. All of these press releases seems to be punched out from the same template and routinely overstate the significance of DDTC registration. Many of these releases, like this one, go so far as to imply that registration constitutes a certification by DDTC that the company has adequate ITAR compliance provisions, as if the registrants had taken and passed a test rather than just sending in the registration fee.

So it is only fair that a company press release on its ITAR registration that, for once, tries to provide an accurate description of the significance of registration should be awarded. And for that very purpose Export Law Blog has created the Reggie Award.

And the first Reggie Award goes to . . .

. . .Envelope please. . .

Prototron Circuits for this press release

Now, with Redmond’s registration in place, we can participate in immediate demand from existing customers on ITAR designs that we previously could not service … . This now allows us to increase our value to our present customer base while increasing our value to prospective customers. …

The award committee noted that this statement in the press release showed a keen understanding that registration was required to manufacture defense articles and was not some optional certificate that the manufacturer obtained after its compliance procedures were reviewed and approved by DDTC. The committee expressed some discomfort with the company’s reference to having “achieved” registration, but felt that this was overcome by the clear acknowledgment of the purpose and benefit of the registration requirement.

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Copyright © 2010 Clif Burns. All Rights Reserved.
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4 Comments:


I can’t help but wonder:

If the regulatory compliance burden on these small businesses were lower in areas of less importance than National Security, would they have more resources to spend in this area and thus avoid falling victim to this “award”?

Comment by ExportMan on May 20th, 2010 @ 9:33 am

I was recently approached by a very large forwarder who cliamed to have expertise in ITAR and had a department who “specialized” in military exports. He asked me if we were “certified” by the DDTC. I mentioned to him that you aren’t certified but we are registered. There was a prolonged silence. I’m sure it’s not surprising I haven’t heard from them again.

So in an effort to look at the glass half full, I’m glad there’s someone who got it right.

Comment by LDM on May 20th, 2010 @ 2:53 pm

LDM,

That’s ironic. Because in my day job, I work for a forwarder, and we get quite a few RFQs from exporters that ask if we are registered with the DDTC. No, there is only DDTC registration for exporters and manufacturers.

Now I suppose we could be the exporter if we filed the export declaration in our own name, but for ITAR controlled items, that would be over my dead body.

Comment by Jim Dickeson on May 20th, 2010 @ 9:32 pm

Jim:

I’m aware of some forwarders who do act as exporters. In most cases it’s to get the business of very large overseas concerns. I agree that would be over my dead body.

My take away from these examples is that there is a lack of training and the opportunity to get trained on ITAR exports. In contrast to the DOC efforts I wonder how many new ITAR exporters even know to look for the DDTC website let alone that their article requires a license for export? Unless someone tells them or they stumble on it, how would they even know the SIA exists and that they are the quasi training arm for the DDTC? Registration – knowing about that is the cherry on the sundae.

Comment by LDM on May 25th, 2010 @ 5:49 pm