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Transition Planning Under Export Control Reform

Transition Planning Under Export Control Reform. Cindy Peeters Trade Compliance Officer. Millitech at a glance. Motorized Waveguide Attenuator. Test Equipment. EAR99. MMW transceiver developed for degraded visual environment (DVE) radar. So you can see through dust.

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Transition Planning Under Export Control Reform

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  1. Transition Planning Under Export ControlReform Cindy Peeters Trade Compliance Officer

  2. Millitech at a glance Motorized Waveguide Attenuator. Test Equipment. EAR99. MMW transceiver developed for degraded visual environment (DVE) radar. So you can see through dust. ITAR because of heritage. Power Dividers Can be commerce or ITAR – depends on heritage. Power Amplifier Could be 3A001 or ITAR depending what MMIC goes inside. Standoff Suicide Bomb Detector for TSA – Passive MMW System 2A983 - CJ Airport runway safety radar. Detects foreign object debris on runway. Currently XIc – ITAR because of see through rule. Antenna for Zumwalt Destroyer ITAR because of heritage.

  3. What we would like from Export Reform • Many of our products become ITAR because of the see through rule. This is where an ITAR component contaminates our commercial assy. • We’re hoping many of these ITAR components, category XIc, will move to the CCL. We could expand our international sales. • Specially Designed?? • Watched the webinar, still trying to decipher. • The hope is our customers will work with us to get things that have been classified as ITAR simply because of heritage, on to the CCL. • Many of our products are lower levels in the assy process and could easily be commerce.

  4. What has worked so far • Millitech is successfully using the new license exception STA, Strategic Trade Authorization, specifically for category 3A001. • The time saved not getting a license helps us to be able to deliver our product on time and has won us some orders that we normally would not have gotten. • What you need: End use statement, Consignee letter, and notification prior to shipment that you will be using STA license exception. • To date, all STA license shipments have been audited by BIS. Keep all your paperwork together and train all personnel involved and you will be successful. • New Brokering Definition: We can now work on ITAR transactions with two of my overseas Reps who did not want to pay to register with the State as a broker so they could not be party to a license.

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