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Export Control

The purpose of this information is to give suppliers and primes one place to go to see the basic information relevant to Nadcap and Export Control. This is a central location for past communications to suppliers and primes as well as other useful information on the subject of Export Control.

General Information

Definition of EC-LR/Restricted: All Defense Articles and Technical Data controlled by the ITAR; any foreign origin Defense Articles and Technical Data that would be controlled by the ITAR if of U.S. origin; any dual-use or civil items or Technology controlled by the EAR under any ECCN except EAR99; and includes any foreign origin dual-use or civil items or Technology that would be controlled by the EAR under any ECCN except EAR99 if of U.S. origin.

When communications etc. refer to “EC-LR/Restricted” the four categories of controls listed in the definition apply to all any of these materials, parts, or processes used by suppliers in connection with Nadcap audits.

It is critical for suppliers to have correctly identified any materials which meet this definition; to report such data to PRI prior to any new Nadcap audits (see form below) and to ensure that only properly licensed materials and information is included in the Nadcap audit.

If suppliers do not have this information, they need to contact their customers to secure it.

Form to report “EC-LR/Restricted” information to PRI (upcoming audits). Suppliers need to complete this form - supplying all requested information to PRI so that the need for licensing can be evaluated.

NOTE: Non US suppliers will always have to supply this information to PRI so the appropriate licenses can be secured. If the supplier is a US supplier – AND PRI Scheduling is sending an Unrestricted auditor (US citizen or permanent resident alien person - green card holder) to do the audit – the form is not required on domestic (US origin) items. If the US supplier has non US origin defense or non US origin commercial items which are going to be available to the audit, licenses may be required. In those cases the supplier needs to complete the applicable tabs on the form & send it to PRI. If a Restricted auditor is scheduled for the US supplier audit – the supplier will need to supply the completed form for all applicable items.

Unless “EC-LR/Restricted” material, parts, technologies, and information is reported on the form to PRI and the appropriate licenses secured before the audit, such material must be excluded from the audit.

It is the responsibility of the suppliers and their customers to properly identify such materials.

Supplier Information

Suppliers have received a number of important communications on Export Control:

May 2, 2008 letter to suppliers. This communication implemented the change as it relates to access to EC-LR/Restricted data for Nadcap auditors.

May 28, 2008 (rev 1) letter to suppliers. In this letter a new category of information has been added - non US origin defense articles to the form.

June 23, 2008 letter to suppliers. This letter which establishes the “final definition of “EC-LR/Restricted” and the suppliers form to report such materials & articles to PRI.

IMPORTANT NOTE: If you have received an e-mail from PRI requesting data on past years audits (back to April 2003) you have until August 8th 2008 to get the information back to PRI. Please send it to donb@sae.org. Information received after August 8th, 2008 may not be included in the final report.

Here are the URLs for the State (ITAR) & Commerce (EAR)

http://pmddtc.state.gov/official_itar_and_amendments.htm

http://www.bis.doc.gov/licensing/exportingbasics.htm

Past Presentations

The last presentations made to NMC and SSC are included here:

Answers to questions raised at the Pittsburgh SSC meeting (Posted August 7, 2008)

EC Roundtable presentation July 24, 2008

Pittsburgh SSC presentation July 22, 2008

NMC Planning & Ops presentation July 22, 2008

Rome NMC presentation Feb 26, 2008

Rome SSC presentation Feb 26 2008

What To Look For

Article in the October Communiqué – Flyer on PRI’s latest efforts to secure licenses for EC-LR/Restricted materials and items.