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ITAR Compliance Checklist (PDF) for Manufacturers, Exporters, Importers, Software and Universities

Use this ITAR compliance checklist to see what applies to your role: manufacturer, exporter, importer, software and ERP administrator, or university. Tick each item, review the critical gaps and export to PDF. It also summarizes the basics of manufacturing license agreements.

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0 of 38 items complete

14 critical items still open - these are the highest-risk gaps.

Download checklist:

Manufacturer or machine shop

Exporter

Importer

Software, IT and ERP access

University, research and training

Manufacturing license agreement and TAA basics

Tick what is done and documented. Critical items are legal gatekeepers: a gap in any of them should be fixed before you ship, share data or start work.

Check your ERP roles against this list

Optional: we can review how your ERP and file shares meet the U.S. person access items.

Optional. The tool and every export work without this. No spam.

What are the ITAR compliance requirements

The ITAR (22 CFR Parts 120 to 130) controls the export, temporary import and brokering of defense articles, technical data and defense services on the U.S. Munitions List. Core requirements are registration with DDTC for manufacturers and exporters, authorization before exporting or releasing technical data to a foreign person, recordkeeping, screening and reporting of violations. The checklist groups these by who is doing the work so each team reads only what applies.

  • Register and keep registration current
  • Classify items and technical data
  • Authorize before any export or foreign person release
  • Keep records and train staff

Software and ERP checklists

Software teams often ask whether ITAR applies to code or cloud tools. Technical data about a defense article, including software that is directly related, is controlled, and release to a foreign person anywhere, including through cloud access, can be an export. For ERP, the practical steps are role-based access limited to U.S. persons, a flag on controlled items, and logging. AI search tools should run on infrastructure you control, with logging and the same role limits as the source system.

Manufacturing license agreement basics

A manufacturing license agreement (MLA) authorizes a U.S. company to grant a foreign person the right to manufacture defense articles abroad, and a technical assistance agreement (TAA) covers defense services and technical data transfers. Both need DDTC approval before any data is shared. They must define parties, territory, articles and technical data, and be amended when anything changes. A small shop is more likely to be the U.S. party in a TAA or the supplier within a larger program than to hold an MLA.

Common mistakes

The most frequent are assuming that a part made to a customer drawing is not controlled, giving foreign national employees access to shared drives, forgetting that a temporary import needs its own authorization, and treating university labs as exempt without a fundamental research determination. Fix the critical items first and re-run the list each quarter.

Frequently Asked Questions

Is there an official ITAR compliance checklist?

DDTC publishes compliance program guidelines rather than a single checklist. This checklist turns those themes into practical items by role. It is a working tool, not an official form, so confirm details with counsel or DDTC.

Does ITAR apply to software?

It can. Software directly related to a defense article is technical data, and releasing it to a foreign person, including through remote access or cloud storage, may be an export that needs authorization.

Do universities need ITAR compliance?

Yes when a project involves controlled defense articles or technical data. Fundamental research that is published broadly can fall outside controls, but sponsor restrictions or controlled inputs change that, so each project needs review.

What is the difference between an MLA and a TAA?

An MLA authorizes foreign manufacture of defense articles under license. A TAA authorizes defense services or technical data transfers to a foreign person without the manufacturing rights. Both require DDTC approval before activity begins.

Where ITAR technical data lives in an on-prem ERP, Netray can add AI search and assistants that run inside your network with the same role restrictions.

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