We 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.