News from Reeves & Dola, LLP 
*** R|D ALERT ***


On January 3, 2017, the Directorate of Defense Trade Controls (DDTC) published a Final Rule to revise the International Traffic in Arms Regulations (ITAR) to require industry to electronically submit import and export data with Customs and Border Protection (CBP) via the International Trade Data System (ITDS). The ITDS is "an electronic information exchange capability or 'single window' through which businesses will transmit data required by participating agencies for the importation or exportation of cargo" (Executive Order 13695, Sec. 3, Feb. 19, 2014). Access to the ITDS system is available through a CBP web portal at: .
Effective December 31, 2016, exporters are required to submit relevant data in ITDS for each import or export, which is a change from the way such information has been submitted to CBP. CBP will then electronically transmit the shipment details relevant to DDTC. As a result, there is no longer a need for exporters to notify DDTC separately for such shipments. Accordingly, the ITAR has been updated throughout to clarify electronic reporting requirements and to remove references to the Automated Export System (AES) and add in its place "U.S. Customs and Border Protection's electronic system(s)." Such updates have been made to relevant sections of Parts 120, 123, and 126.
The implementation of the ITDS system should streamline this process and reduce reporting burdens sometimes experienced by industry. Companies should carefully review the new requirements, in conjunction with this Alert.
This Alert provides a brief summary of the changes made to the ITAR, but is not intended to be a substitute for reviewing the Federal Register Notice or the ITAR.                  

The above alert is for informational purposes only and is not intended to be construed or used as legal advice. Receipt of this alert does not establish an attorney-client relationship. 

Questions about this alert can be directed to: 

Johanna Reeves: 202.715.9941  | [email protected]
Katherine Heubert:    202.715.9940   [email protected]
About Reeves & Dola

Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs.

Reeves & Dola, LLP
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