Loose Lips: Do They Sink Ships or Just Annoy DDTC?

Posted by at 6:23 pm on March 1, 2012
Category: DDTCPart 122

Top SecretWe all know about exporters who, having spent the money to register with the Directorate of Defense Trade Controls (“DDTC”), can’t resist crowing about it, with some even implying in press releases that registration is a certification from DDTC that the registered exporter has passed some test and is now certified as ITAR-compliant, which, of course, is untrue.

But here’s another response to the giddy euphoria that follows on the heels of a successful registration: post the registration code and the DDTC registration letter on your website! That is exactly what E.R. Precision Optical did. Of course, the folks at E.R. were probably not aware that DDTC says

The code is proprietary to the registrant and should be handled as such. Company registration codes should not be posted online or given out freely to the public.

Of course, that raises the more interesting question: why should this registration number be confidential? It’s not like I can take E.R.’s number from the web and use it to start applying for export licenses in my own name. Further, DDTC spokespeople have said that exporters should make sure that they only deal with registered subcontractors even though DDTC refuses to answer inquiries as to whether particular parties are even registered or not. And arguably using an unregistered manufacturer is a violation of section 127.1(d) of the ITAR.

So how do you find out if someone who manufactures defense articles is registered? The best way is to ask that company for a copy of the registration letter which, of course, the DDTC says is “double secret.*” Otherwise, you just have to take their word for it. At least when companies like E.R. post the registration letter and code online, you can be fairly certain, Photoshop forgeries aside, that they are registered.

[h/t to Chris Adams for pointing out the E.R. website to me.]

*Naughty language alert if you click this link and view the video. May not be safe for certain workplaces.


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Copyright © 2012 Clif Burns. All Rights Reserved.
(No republication, syndication or use permitted without my consent.)


Did you notice the nifty “ITAR Registered” logo on E.R.’s web page? I didn’t know there was such a thing. Where can I get my ITAR Registered coffee mug and t-shirt?

Comment by Mike S. on March 2nd, 2012 @ 9:12 am

Clif, the reason companies may want to keep their registration # confidential is that ELLIE is still alive and well. ELLIE requies ONLY a registration to log in on the internet, and anyone in the business knows this. While there is not a ton of info in there, they could potentially log in and see minimnal info about certain pending applications with DDTC. I do not give out my registration code because I don’t want people looking at my ELLIE a/c. GCs, AOs still get logged and tracked in ELLIE []. Back in the day it was license apps and CJs too. An acceptable substitute is to dispense copies of the registration letter with the number blacked out, or to simply sign a separate certification that “yes we are registered and our expiration date is xxx”.

Comment by shelley on March 2nd, 2012 @ 10:40 am

Clif, as I said in my other email to you, I plan to make a new ITAR logo. It’ll be a skull and crossbones. On the top it’ll say “ITAR REGISTICATED!” and on the bottom it will say “ABANDON ALL HOPE.” On a more serious curiosity question – whenever I read the ITAR I always think to myself “based on this, isn’t ever gun shop in the United States that sells tactical rifles and handgun required to register with DDTC?”

Comment by Chris Adams on March 2nd, 2012 @ 2:13 pm

    Only if the gun shop either “manufactures” or “exports” the rifles and handguns that it is selling.

    Comment by Clif Burns on March 2nd, 2012 @ 2:51 pm