What is DTrade and How does it Impact My FFL Firearm Export BusinessLast time, we promised to get into the nuts and bolts of exporting firearms and ammunition products and related technical data and defense services. The first step is to introduce you to DTrade. DTrade is the web-based portal that registrants use to apply for export licenses from DDTC. Let’s stop for a moment. Note that DTrade is the way registrants apply for export licenses. Don’t overlook that point. We have previously advised that if you manufacture firearms, firearms components, accessories or ammunition, you most likely need to be registered with DDTC. If you want to obtain an export license, you must be registered. After you have registered with DDTC, in order to apply for export licenses you have to register separately with DTrade and take a few other preliminary steps. Start by going to the DTrade Information Center on the DDTC website. The DTrade Information Center is the first place you want to look for answers to any questions about DTrade. In the upper right corner of the DTrade Information Center homepage you will see a link to Getting Started with DTrade. Clicking on that link takes you to a document entitled DTrade Electronic Licensing System. (Note the last sentence of the first paragraph of this document: “Knowledge of the ITAR and DDTC Defense Trade Function are necessary for DTrade use.” In other words, registrants who intend to use the DTrade export licensing portal are expected to take appropriate steps to be knowledgeable about the ITAR.) The Getting Started with DTrade document tells you that in order to use DTrade, you must obtain an ACES Digital Certificate and install it on your computer. The document identifies two private vendors from whom the Digital Certificate can be obtained. The annual cost is a little over $100. Unless you are in a rush, allow a week to prepare the application and await issuance of the certificate. Once you have received the Digital Certificate, follow the Getting Started with DTrade instructions carefully for installing the Digital Certificate and registering it with DTrade. If you have an IT department, this is a job for them. Note that you want to install the certificate on the computer that will be used for accessing DTrade and submitting license applications. The next thing you need to do is to assign someone in your company to be the DTrade “Super User”. The process for doing this is explained in detail in the Getting Started with DTrade document, but, in short, a senior official of the company sends DTrade a letter on company letterhead designating an employee to be the Super User. That designation is then approved by DTrade and the named individual is assigned by DTrade to the Super User role. A small company that will file for licenses only infrequently requires one user, the designated Super User. A larger company can have multiple Super Users and even more Users. In a small company, the Super User should be a trusted senior administrative employee, as that person will also be the one preparing export licenses. This individual will be the primary interface with the DDTC licensing staff and will need to be well-trained in the company’s ITAR responsibilities. (Note that authority to sign a license application is something different. Only an “Empowered Official” is allowed to sign a license application, so designating a Super User does not carry with it a delegation of authority to sign export license applications.) DTrade’s Getting Started with DTrade document ends at this point, but you’re really not finished. There’s one more step. Accessing license forms at the DTrade website requires a particular viewer that has to be downloaded and installed on your computer. You can find the instructions for this at the DTrade Information Center. If you scroll down at that site, you will see a heading on the right side for “DTrade Form Viewer” under which there are links to a download site for the Form Viewer and to installation instructions. You’ll probably save yourself some trouble if you actually read these instructions and follow them before charging off to install the viewer. You will know you have reached your final destination when you can log in to the website at this link: https://dt2.pmddtc.state.gov/dtrade/CertificateLogin. That’s where you can access the DSP-5 and other principal license forms so can prepare and file export licenses. There are additional informational materials at the DTrade Information Center website. Questions that aren’t answered there can be directed to a professional or to the DTrade Help Desk at DTradeHelpDesk@state.gov or by phone at 202-663-2838. We will walk through a DSP-5 in an upcoming advisory but before that we will digress briefly to look at the role of “Empowered Officials” in the licensing process. That will be the subject of the next advisory in our ITAR series.
By Jeff Grody Principal and Export / ITAR Practice Lead Orchid Advisors assists firearms manufacturers, distributors and retailers in achieving compliance and operational excellence through education, technology, software and consulting solutions that reduce risk, cut costs, and provide expert guidance to make our client’s business more successful and efficient.
Other Firearm ITAR / Firearm Export Articles
- Five Common Firearm Itar / Export Violations You Might Not Know About
- Former DDTC Comments on Firearms Export Compliance
- Firearm Export Licensing 101 and What is DTrade?
- What is ITAR and How Does It Relate to Firearm Exports
- What Features Should Your Firearm Itar Compliance Program Contain
- Does ITAR Apply to My FFL Business