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DDTC (Directorate of Defense Trade Controls): ITAR Registration and Reporting

What DDTC does, who must register under 22 CFR 122, the research exemption, and how voluntary disclosure works.

Written and maintained by CASRAI Editorial Board

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DDTC is the Directorate of Defense Trade Controls, the U.S. State Department office that administers the International Traffic in Arms Regulations (ITAR). Research-security and sponsored-programs staff meet it when a project involves defense articles, defense services or ITAR-controlled technical data. (Not to be confused with the Indonesian tax consultancy and research site of the same acronym; this page covers the U.S. export-control agency only.)

Who is the DDTC?

Under 22 CFR 120.1, the Secretary of State delegates authority to administer the ITAR to the Deputy Assistant Secretary of State for Defense Trade Controls in the Bureau of Political-Military Affairs. That official supervises the Directorate of Defense Trade Controls, which the regulation describes as made up of offices for licensing, compliance and policy. The statutory authority is Section 38 of the Arms Export Control Act (22 U.S.C. 2778), which authorizes the President to control exports and imports of defense articles and defense services; Executive Order 13637 delegates the regulation-making part of that authority to the Secretary of State.

What does ITAR stand for?

ITAR stands for the International Traffic in Arms Regulations, codified at 22 CFR Parts 120-130. They implement the Arms Export Control Act and are administered by DDTC. The items they control are listed on the U.S. Munitions List; see the ITAR and U.S. Munitions List guide and our ITAR regulations overview for scope and classification.

What DDTC’s three offices do

Office (22 CFR 120.1(b)(2)) Responsibility as described in the regulation
Office of Defense Trade Controls Licensing Licensing or other approvals of defense trade
Office of Defense Trade Controls Compliance Violations of law or regulation and compliance, including registration
Office of Defense Trade Controls Policy General policies of defense trade

Who must register with DDTC?

Under 22 CFR 122.1(a), any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, must register with DDTC. One occasion is enough to count as engaging in that business, and a manufacturer that does not export must still register.

Exemptions that matter to universities

Section 122.1(b) lists four exemptions: U.S. Government officers and employees acting in an official capacity; persons whose business is confined to producing unclassified technical data only; persons whose manufacturing and export activities are all licensed under the Atomic Energy Act; and persons who fabricate articles solely for experimental or scientific purposes, including research and development. The regulation’s note adds that persons using the technical-data or research exemptions still need licenses or approvals for exports and cannot receive an export license unless registered. Whether a particular lab falls inside an exemption is a classification and legal question for the institution’s empowered official, not something this page can decide.

Registration is not permission to export. Section 122.1(c) states that it gives the government information on who is involved and “does not confer any export rights or privileges”, though it is generally a precondition to any license or approval.

How to register for ITAR

The rules in 22 CFR 122.2 set out the mechanics:

  1. Submit a Statement of Registration (Department of State form DS-2032) to the Office of Defense Trade Controls Compliance, following the electronic filing instructions on the DDTC website at www.pmddtc.state.gov.
  2. Have it signed by a U.S. person senior officer (for example a president, secretary, treasurer or general counsel) empowered by the registrant to sign such documents.
  3. Include documentation showing the registrant is incorporated or otherwise authorized to do business in the United States.
  4. Include the certification in 122.2(b): whether the registrant or its listed affiliates, senior officers or directors have been indicted, charged or convicted under the enumerated criminal statutes, or are ineligible to contract with or receive licenses from the U.S. Government, and whether the registrant is foreign owned or controlled.
  5. If DDTC finds the submission incomplete, it will tell the registrant what is missing or return the whole package (122.2(c)).
  6. Renew annually and pay the registration fee: send the renewal request at least 30 days but no earlier than 60 days before expiry; DDTC sends notice of the fee due at least 60 days before expiry (122.2(d)-(e)). Registering again after a lapse requires paying fees for any intervening period in which the registrant was in the business (122.2(f)).

Registrants may not set up new entities to reduce registration fees (122.2(a)). Fee amounts are published by DDTC and change, so use the current schedule there rather than a third-party figure.

How to report an ITAR violation

There are two distinct routes, often confused.

Voluntary disclosure by the organization

Under 22 CFR 127.12, the Department “strongly encourages” persons who believe they may have violated the Arms Export Control Act or the ITAR to disclose to DDTC, and a voluntary disclosure may be considered a mitigating factor. The sequence in 127.12(c)(1) is an initial notification immediately after a violation is discovered, followed by a full disclosure within 60 calendar days of that notification (an extension can be requested in writing). Limits: it applies only if DDTC receives the information before another agency learns of the same or substantially similar information and begins an inquiry; it must be made with the full knowledge and authorization of senior management to count as voluntary; DDTC has sole discretion over whether it mitigates; and referral to the Department of Justice remains possible. Disclosure creates no enforceable rights.

Reporting by an individual

A researcher or employee who is not making the institution’s disclosure should read export-control whistleblower protections in research before acting.

Where to find the DDTC portal and sign-in

DDTC’s public site is www.pmddtc.state.gov; the regulation (122.2(a)) directs registrants to the electronic filing instructions there, and the sign-in for registrants and license applicants is reached from that site.

Strengths and limits of DDTC as a reference point

  • Strength: it is the single authority for ITAR registration, licensing approvals and compliance matters, so its own pages and the eCFR text are the definitive sources.
  • Limit: it covers defense articles and services on the U.S. Munitions List; dual-use items fall under a different regime (below).
  • Limit: registration status does not answer whether a specific research activity needs a license; that depends on classification and the people and countries involved. See ITAR and EAR compliance for university research.

Alternatives: DDTC and the Commerce Department regime

DDTC Bureau of Industry and Security (BIS)
Department State Commerce
Regulations ITAR, 22 CFR Parts 120-130 EAR, 15 CFR Parts 730-774

For a full comparison see ITAR vs EAR.

FAQ

How do I register for ITAR?

File Statement of Registration form DS-2032 with DDTC’s Office of Defense Trade Controls Compliance using the electronic filing instructions at www.pmddtc.state.gov, signed by an empowered U.S. person senior officer (22 CFR 122.2).

What does ITAR stand for?

International Traffic in Arms Regulations (22 CFR Parts 120-130).

Who is the DDTC?

The Directorate of Defense Trade Controls in the State Department’s Bureau of Political-Military Affairs, which administers the ITAR under the Arms Export Control Act.

How do I report an ITAR violation?

An organization makes a voluntary disclosure to DDTC’s Office of Defense Trade Controls Compliance: initial notice immediately after discovery, full disclosure within 60 calendar days (22 CFR 127.12). Individuals should see the whistleblower guide linked above.

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