Effective February 14, 2022, the Directorate of Defense Trade Controls (DDTC) has posted an update to its “Guidelines for Preparing Agreements” that provides guidance for submitting and handling of ITAR Technical Assistance Agreements (TAAs), Manufacturing Licensing Agreements (MLAs), and Warehouse and Distribution Agreements (WDAs).

These ITAR export authorizations are required for a U.S. individual to provide an ITAR “defense service” to a foreign person, including providing ITAR “technical data,” an authorization to manufacture defense articles abroad, or to establish a distribution point abroad for defense articles of U.S. origin for subsequent distribution to foreign persons.

These Agreement Guidelines are related to the firearm and ammunition industry as the ITAR identifies automatic firearms, suppressors, certain firearm and suppressor related parts and components, 51-round and larger magazines, and ‘military grade’ ammunition, including steel core and tipped projectiles and ammunition, as “subject to the ITAR” export controls and compliance requirements.

Revision 5.0 is the first revision made to the Agreement Guidelines since 2018 and is intended to provide restructured guidance via “Agreement Guidelines in a more logical and orderly fashion.” Additional DDTC clarification is included that supports application processing and agreement handling with a full summary of changes provided on page 1 of the posted “Guidelines for Preparing Agreements” Revision 5.0.

For assistance obtaining import and export licensing, sourcing firearm parts and tooling from international vendors, or complying with State Department (ITAR) and Department of Commerce (EAR) regulations, contact Orchid today to connect with our ATF or U.S. export experts.