Export Control Regulations

PRI Registrar fully complies with all Export Control regulations and laws. The purpose of this information is to give suppliers a central location for General Information about PRI Registrar's Export Control system. In addition, there are links to government web pages as well as other useful information on the subject of Export Control.

General Information

In general, the PRI policy and process regarding control of Export Controlled/Restricted materials is that suppliers are responsible to know the status of all such materials, information, etc. in their possession and to safeguard it as per the regulations. If suppliers are unaware of the status of their materials and technical data, they are to contact their customers.

Even though the PRI Registrar audits are quality systems audits, suppliers must safeguard Controlled/Restricted materials during the audit as required by the laws and regulations. Auditors may come in contact with such information as they audit various elements of the suppliers' manufacturing and quality systems.

PRI asks whether the supplier has Export Controlled/Restricted materials as part of the application process.

Some important excerpts from the ITAR:

120.3 Policy on designating and determining defense articles and services.

An article or service may be designated or determined in the future to be a defense article (see 120.6) or defense service (see 120.9) if it:

(a) Is specifically designed, developed, configured, adapted, or modified for a military application, and (i) Does not have predominant civil applications, and (ii) Does not have performance equivalent (defined by form, fit and function) to those of an article or service used for civil applications; or

(b) Is specifically designed, developed, configured, adapted, or modified for a military application, and has significant military or intelligence applicability such that control under this subchapter is necessary.

The intended use of the article or service after its export (i.e., for a military or civilian purpose) is not relevant in determining whether the article or service is subject to the controls of this subchapter. Any item covered by the U.S. Munitions List (USML) must be within the categories of the U.S. Munitions List.

120.6 Defense article.

Defense article means any item or technical data designated in 121.1 of this subchapter (The USML). The policy described in 120.3 is applicable to designations of additional items. This term includes technical data recorded or stored in any physical form, models, mockups or other items that reveal technical data directly relating to items designated in 121.1 of this subchapter. It does not include basic marketing information on function or purpose or general system descriptions.

Some Important excerpts from the EAR:


In this part, references to the Export Administration Regulations (EAR) are references to 15 CFR chapter VII, subchapter C. The EAR are issued by the United States Department of Commerce, Bureau of Industry and Security (BIS) under laws relating to the control of certain exports, re-exports, and activities. In addition, the EAR implement antiboycott law provisions requiring regulations to prohibit specified conduct by United States persons that has the effect of furthering or supporting boycotts fostered or imposed by a country against a country friendly to United States.

(1) How do you go about determining your obligations under the EAR?

Part 732 of the EAR provides steps you may follow to determine your obligations under the EAR. You will find guidance to enable you to tell whether or not your transaction is subject to the EAR and, if it is, whether it qualifies for a License Exception or must be authorized through issuance of a license.


URLs for the U.S. Department of State (ITAR) and Commerce (EAR)

161 Thorn Hill Road - Warrendale PA - 15086 - Phone: 724-772-1616 - Fax: 724-772-4080