Suppliers, Nadcap and Export Control

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Suppliers, Nadcap and Export Control

• DonB
• Supplier Support
• Committee meeting
• Pittsburgh, PA
• July 22, 2008
• (note some of these slides were not reviewed
• in the Pittsburgh SSC mtg due to time
  restrictions)

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Topics

• New definition EC-LR/Restricted
• New form to report EC-LR/Restricted materials to
  PRI
• Explanation of the licensing process via a flow
  chart
• New WEB pages

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EC-LR/Restricted definition

• All Defense Articles and Technical Data
  controlled by the ITAR

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EC-LR/Restricted definition

• All Defense Articles and Technical Data
  controlled by the ITAR any foreign origin
  Defense Articles and Technical Data that would be
  controlled by the ITAR if of U.S. origin

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EC-LR/Restricted definition

• All Defense Articles and Technical Data
  controlled by the ITAR any foreign origin
  Defense Articles and Technical Data that would be
  controlled by the ITAR if of U.S. origin any
  dual-use or civil items or Technology controlled
  by the EAR under any ECCN except EAR99

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EC-LR/Restricted definition

• All Defense Articles and Technical Data
  controlled by the ITAR any foreign origin
  Defense Articles and Technical Data that would be
  controlled by the ITAR if of U.S. origin any
  dual-use or civil items or Technology controlled
  by the EAR under any ECCN except EAR99 and
  includes any foreign origin dual-use or civil
  items or Technology that would be controlled by
  the EAR under any ECCN except EAR99 if of U.S.
  origin.

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New form to report EC-LR/restricted materials

• Once the supplier has signed the supplier
  agreement in eAuditNet, the following question
  must be answered

When you click here
This is scheduled to be in place in the 4th qtr
2008
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Form to report EC-LR items to PRI

• Suppliers are to review all their parts, items
  which would be available to the Nadcap audit (all
  parts which use the processes being audited), and
  submit them to PRI on the appropriate tab on
  this form

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Licensing process
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The key Issue

• supplier knowledge of the EC-LR/Restricted status
  of their materials technology

• Only way suppliers can get the proper status is
  from their customers

• Without this information, suppliers cannot
  properly report items needing licenses to PRI
• Without the items being reported, PRI licenses
  will not cover all items which are needed to be
  audited

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What is the main cause of the issue?

• Poor FLOW DOWN

Next cause is lack of supplier understanding of
EC regulations
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New WEB page

• Export Control page on PRI/Nadcap web
• http//www.pri-network.org/PRI/
• Nadcap
• About Nadcap
• Export Control (http//www.pri-network.org/Nadc
  ap/Export-Control.id.879.htm)

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Questions?

• Don Buehler
• donb_at_sae.org
• 513-662-5190 (phone)
• 513-305-7493 (cell)