ITAR Registration With DDTC: Who Needs It, How It Works, What It Costs

Who must register with DDTC

Under 22 CFR 122.1, anyone who engages in the United States in the business of manufacturing, exporting or temporarily importing defense articles, or furnishing defense services, must register. The rule says one occasion is enough to count as being in the business.

The line that catches small shops is this one: a manufacturer who does not export must still register. A machine shop that makes a part which is itself a defense article on the US Munitions List is manufacturing a defense article, even if the part goes straight to a domestic prime two counties away.

The regulation lists four exemptions:

• US government officers and employees acting in an official capacity.
• Persons whose relevant business is limited to producing unclassified technical data only.
• Persons whose manufacturing and export activities are all licensed under the Atomic Energy Act.
• Persons who fabricate articles solely for experimental or scientific purposes, including research and development.

Even exempt persons stay subject to licensing rules, and DDTC will not issue them a license unless they register. Brokers have their own registration requirement under 22 CFR part 129.

First question: is the part ITAR or EAR?

Registration only matters if the work involves defense articles or defense services on the US Munitions List. Plenty of aerospace and defense parts are not.

Starting in 2013, export control reform moved many military aircraft and engine parts, and later other categories, from the Munitions List to the Commerce Control List under the Export Administration Regulations. They now sit in the "600 series" export control classification numbers. Work on those items is controlled by the Commerce Department, not DDTC, and does not by itself trigger DDTC registration, although EAR rules still apply to exports and to sharing technology with foreign persons.

As a supplier you rarely classify the part yourself. The design owner does. Ask the buyer for the export jurisdiction and classification on the RFQ or purchase order. If the paperwork says ITAR or cites a USML category, plan on registering before you cut chips.

DDTC registration fees

The fee schedule in 22 CFR 122.3 was raised by a final rule published December 10, 2024, effective January 9, 2025. It was the first fee change since 2008.

Example: a renewing registrant with eight favorable determinations pays $4,000 plus three times $1,100, or $7,300.

A typical build-to-print job shop that only manufactures for domestic customers will not be applying for export licenses, so it pays the Tier 1 fee each year.

Small business relief. In the same rule, DDTC announced a one-year initiative letting Tier 1 registrants petition for a $500 discount, for a $2,500 fee, if $3,000 was 1 percent or more of their total revenue for the last calendar year. Requests had to reach DDTC at least 30 days before the current registration expired. Because it was announced as a trial, check the DDTC website to see whether it is still offered before counting on it.

How to register, step by step

1. Confirm you need to. Get the jurisdiction and classification of the parts or services from your customer.
2. Pick a signer. The Statement of Registration (form DS-2032) must be signed by a US person senior officer empowered to sign, such as the owner, president or a partner.
3. Gather documents. Include proof that the company is incorporated or otherwise authorized to do business in the United States, plus details on ownership, officers and directors, and any subsidiaries or affiliates you include.
4. Answer the certifications. The senior officer certifies whether the company or its leadership has been charged with or convicted of listed export crimes, whether anyone is barred from government contracting or export privileges, and whether the company is foreign owned or controlled.
5. File electronically through the DDTC system at pmddtc.state.gov and pay the fee using DDTC's payment guidance.
6. Respond to DDTC. If the package is incomplete, DDTC tells you what is missing or returns it.

DDTC does not publish a guaranteed processing time, so start well before you need to quote ITAR work. You may not set up a new entity just to cut registration fees, and subsidiaries more than 50 percent owned or otherwise controlled can be listed on one registration.

Keeping registration current

• Renew every year. Submit the renewal at least 30 days but no earlier than 60 days before expiration.
• Do not let it lapse. If you keep manufacturing defense articles while unregistered, you owe fees for that gap when you come back.
• Report changes within five days. Name, address, legal structure, ownership or control, board members and senior officers, and certain subsidiary changes must be reported in writing within five days of the event.
• Give 60 days notice by registered mail before any intended sale or transfer of ownership or control to a foreign person.
• Keep records five years. Under 22 CFR 122.5, registrants keep records of the manufacture, acquisition and disposition of defense articles and technical data, and must produce them on request.

What registration does not do

Registration is a notice to the government that you are in the business. The regulation says it confers no export rights or privileges. It is mainly a precondition for licenses.

It also does not authorize you to share ITAR technical data with foreign persons. Showing a controlled drawing to a foreign national employee, or emailing it to an overseas programmer, can be an export that needs a license. Shops doing ITAR work generally need:

• A way to confirm who on staff is a US person before they see controlled data.
• Physical and IT access controls on drawings, models and CNC programs.
• Marking and handling procedures so controlled data does not leak into quoting email or shared drives.
• Training, and a named person who owns export compliance.

Those controls overlap heavily with CMMC Level 2, because ITAR technical data on DoD programs is typically CUI. Our CMMC cost guide covers that side.

What ITAR registration really costs a small shop

The government fee is the predictable part: $3,000 a year at Tier 1. The variable part is the compliance program around it: someone's time to run it, IT controls for controlled data, training, and outside counsel when a classification question comes up. Most of that is shared with work you need anyway for getting on a prime's approved supplier list, where buyers commonly ask about export compliance during qualification.

Tell buyers you are registered

When you join Aerospace Sourcing free, note your DDTC registration status and whether your staff on controlled work are US persons. We only route controlled work to suppliers who can handle it. ITAR, EAR and CUI data never move through our website; they go by secure transfer to US persons only, after the supplier signs a flow-down NDA. We review each signup and contact you when a job fits.

More on the requirements buyers check: the aerospace supplier guide and the supplier readiness checklist.

Questions

Related

• CMMC Certification Cost, Levels and Timeline for Small Shops
• How Shops Get on a Prime's Approved Supplier List
• Aerospace Supplier Readiness Checklist

Sources

• eCFR: 22 CFR part 122, Registration of Manufacturers and Exporters
• eCFR: 22 CFR part 129, Registration and Licensing of Brokers
• Federal Register: ITAR Registration Fees final rule (Dec. 10, 2024)
• Directorate of Defense Trade Controls (DDTC)
• Federal Register: Commerce rule creating the first 600 series ECCNs (Apr. 16, 2013)