This month, DDTC has introduced new versions of several different forms for exporters to use with their ITAR licenses and registrations. It’s important to use these new versions of the documents, because DDTC will no longer be accepting the previous versions.
Here’s a brief summary of the new documents:
- New DDTC Registration Form: Effective October 25, 2013, a new DS-2032 registration form will be published for use. This form is Version 4.0. Older versions of the DS-2032 form will not be accepted if submitted after the effective date. The new form may be submitted either electronically (via EFS), by registered mail, or express mail until December 31, 2013. However, effective January 1, 2014, only electronic submissions will be permitted. Version 4.0 includes several modifications for those who are applying for or renewing their DDTC registration. This includes the ability for U.S. persons to consolidate manufacturer/exporter/broker registrations; updates to ITAR USML Categories; disclosure of intermediate through ultimate parents; a certification regarding debarred or subsequently reinstated parties; a certification on violations involving any U.S. criminal statutes; as well as clarification on foreign ownership.
- New License Forms: Effective October 13, 2013, DTrade2 has been upgraded to a new version, which includes new versions of the DSP-5, DSP-6, DSP-61, DSP-62, DSP-73 and DSP-74 license application forms. These forms are Version 7.1. Exporters filing applications via Form Version 6.0 or earlier after October 14, 2013, will have those submissions rejected and will be required to resubmit using the correct Version 7.1 form.
It’s important to make note of these new forms and correct your internal processes, as needed, to avoid costly delays in the processing of your ITAR registration or license application with DDTC.
Tom Reynolds is the Vice President of Operations for Export Solutions, a consultancy firm which specializes in ITAR and EAR compliance.