ITAR Registration: What It Regulates and Audit Requirements

There are many registrations out there that keep importing, exporting, and manufacturing running smoothly and to certain standards—but sometimes it’s difficult to keep track of what your company needs to be signed up for. For those in the defense sector, the International Traffic in Arms Regulations (ITAR) is a standard regulation body you’ll need to be registered with. The ITAR oversees a wide range of products, services, and technologies that are related to defense purposes, all of which can be found on the United States Munitions List (USML). Not only that, but it helps uphold compliance across companies working in this industry. Here is all you should know about registering, what industries must do so, and similar accreditation and registrations that might be helpful, too.

What Is an ITAR Registration?

This is registration under the International Traffic in Arms Regulations, and there are a few steps involved. You’ll first have to fill out a Directorate of Defense Trade Controls (DDTC) registration form, submit specific documents, and pay a registration fee of $2,250. You can expect to share the types of activities your company takes part in and the products or services it provides that are related to the USML list and those that aren’t, as well as the places you do business in and outside of the country. 

Once you have registered with the DDTC, your company will then have to comply with standards monitored by ITAR (there are plenty of guides and documentation out there that’ll help you do so). Part of this is creating an export compliance program in order to get the license you need to export your defense-related goods or services. 

Aside from it being a legal requirement with penalties if not adhered to, there are lots of benefits to registering. Government agencies and defense contractors prefer ITAR-registered companies, so your company will have a better chance of working on highly profitable projects in the defense industry without worrying about legal issues. The accreditation tells potential clients that you are a credible and trustworthy business. Registering also gives your company access to DDTC-regulated training and resources and it can even help you expand internationally.

Types of Registrations

There are two types of ITAR registration: manufacturing and export, which are relatively self-explanatory. A manufacturing ITAR registration is needed for any company that’s making and producing the actual products, services, software, and technologies involved in defense and covered on the USML. Even if you’re only one of the companies involved or only take part in development or assembly, you’ll still need to register.

An export registration is for companies that export the products, services, and technologies that are on the USML. Again, it includes businesses that may only play one part in the shipping or only focus on arranging transportation or freight forwarding. There are a few exceptions so it’s best to reach out to the organization directly to know if you should register or not. 

Industries and Companies ITAR Impacts

How do you know if your company must be registered with ITAR? The USML is a great place to start. If your products and services aren’t part of this list, you likely aren’t required to register. Below, we’ve put together a list of some of the most common technologies and products that have to be registered and audited:

• Any aerospace or defense company that manufactures or exports military aircraft, helicopters, drones, and the technologies related to these vehicles
• Manufacturers and developers who make engine and propulsion systems
• Any military vehicle manufacturers who create armored vehicles, tanks, and other ground transport vehicles
• Manufacturers of small arms who make weapons for the military or law enforcement sector
• Tech and service-based companies that develop analytical, targeting, strategic analysis, navigation/guidance, software security, and cryptosystems used in military equipment or applications
• Companies that make or export satellite systems, radar, sensors, or similar technologies that get used in a military or intelligence setting
• Manufacturers who produce defense-related wearables, whether that’s body armor, vision systems, comm systems, physical enhancements, or biometrics reporting devices and software

Categories That Require Registration

ITAR registration spans a long list of items, technologies, and software, including the following from the USML list:

• Firearms, close assault weapons, and combat shotguns
• Guns and armament 
• Ammunition/ordnance
• Surface vessels of war and special naval equipment
• Explosives and energetic materials, propellants, incendiary agents, and their constituents
• Ballistic missiles, bombs, launch vehicles, guided missiles, rockets, torpedoes, and mines
• Ground vehicles
• Aircraft and related articles
• Military training and equipment
• Personal protective equipment
• Military electronics
• Fire control, range finder, optical and guidance and control equipment, and night vision goggles
• Materials and miscellaneous articles
• Toxicological agents, such as chemical agents, biological agents, and associated equipment
• Spacecraft and related articles
• Nuclear weapons and related articles
• Classified articles, technical data, and defense services not otherwise enumerated
• Directed energy weapons
• Gas turbine engines and related equipment 
• Submersible vessels and related articles
• Articles, technical data, and defense services not otherwise listed

ITAR Audit Criteria

When you’re going through an ITAR audit, you’ll want to make sure your company has the following documentation, practices, and systems in place:

• Have an export compliance program
• Keep records of exports, agreements, licenses, and finances
• Have employee training programs and regulatory awareness as a pillar of your company so everyone is aware of these practices (whether or not the company is getting audited)
• Ensure there are security and safety measures in all of your company’s buildings and facilities, including ways to show that materials and products are secured from unauthorized access 
• Establish security measures for your IT systems to protect them from cyberattacks and internal theft
• Ensure the company has systems in place to manage subcontractors safely and securely, as this will likely come up in the audit, too 
• Records of the company’s business practices and operations so they can be checked for ITAR compliance

How the Process Works

After you get your documentation and processes in order, you’ll be ready to go on to the audit and accreditation portion. While it’ll vary slightly based on the company you have, these are the general steps you can expect:

1. Registration: First, you’ll submit the registration form and payment to the DDTC to begin the ITAR compliance process. 
2. Pre-assessment: The DDTC might first review your company and its export compliance programs to see if an audit is necessary. 
3. Audit notification: If the DDTC determines the company needs an audit, it will let you know and give you a time frame of when you can expect it.
4. Onsite audit: The audit will take place, which normally involves employee interviews, inspection of facilities and buildings, and looking over documentation. 
5. Audit report: This will give you and your company a good idea of your standing and if there are any areas of non-compliance that need to be fixed before you can be registered. 
6. Corrective action plan: If there are any non-compliant findings, your company will have to put together an action plan that gets signed off by the DDTC. 
7. Accreditation: Once that action plan is implemented, you may need another audit, or the DDTC will officially accredit you with ITAR compliance. 

After you’re accredited, your company will have to undergo a new audit every three years. With the right practices and standards in place and upheld, there should be very few obstacles in the way of renewing the accreditation. 

Similar and Related Registrations and Accreditations 

These registrations and accreditations are similar in nature or often go hand in hand with ITAR, so it’s best to check if you need any of the following for your company:

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