Who Must Register
Any U.S. person engaged in the business of manufacturing, exporting, or brokering defense articles or defense services must register with DDTC under 22 CFR Part 122. This includes manufacturers of defense articles even if they do not export, as well as brokers who facilitate defense trade transactions.
Registration is a prerequisite for applying for any ITAR license or agreement. You cannot apply for a DSP-5, TAA, or any other authorization without an active DDTC registration.
The Registration Process
Registration is submitted through DDTC's online portal. You must provide company information, a description of defense articles manufactured or exported, facility locations, and information about officers and key personnel. The registration must be renewed annually.
The current registration fee structure includes a base fee that varies depending on the type and volume of defense trade activities. Late renewals and lapsed registrations can result in compliance complications and potential enforcement actions.
Consequences of Non-Registration
Engaging in ITAR-controlled activities without proper DDTC registration is a violation that can result in civil penalties up to $500,000 per violation and criminal penalties including imprisonment. DDTC takes registration compliance seriously as it forms the foundation of the defense trade control system.
If you discover that your company should have been registered but was not, consult with an ITAR attorney about the appropriate remediation steps, which may include a voluntary self-disclosure to DDTC.