International Traffic in Arms Regulations

Effective October 15, 2013, most aerospace fasteners will no longer be listed on the USML or the CCL. This includes all PennEngineering fasteners. When additional USML categories are updated, other fasteners currently controlled by the USML or CCL will be excluded because the definition of “specially designed”, including the fastener exclusion, will remain consistent throughout the revised export control regulations.

The key factor in determining whether parts such as fasteners will continue to be subject to either Department of State’s USML or Department of Commerce’s CCL hinges on whether they are “specially designed” for a military item that is subject to export controls. In the final rules issued on April 16, the “specially designed” definition contains specific language excluding fasteners from the definition. Therefore, according to this language, ITAR regulations are not applicable to PennEngineering fastener products.