Third Question: What is the obligation of the manufacturer if they decide to sub contract out to another manufacturer to have the component/part made?
Fourth Question: How does this scenario affect EAR 99 with NLR. First Answer: If the parent item is a defense article, it is likely that the child item is specially designed for an ITAR item which means the child is a defense article. That means the child drawing is ITAR controlled. The ITAR does not require that you mark drawings as ITAR controlled unless you export them. It is a prudent business practice to do so even though it is not required. Second Answer: The ITAR does not require that you notify other US parties that you are acquiring raw materials to make an ITAR item. I would assume much of the raw materials are not ITAR, but I cannot tell here. If you give suppliers ITAR tech data (e.g., drawing), it would be a prudent business practice to let them know you are giving them ITAR tech data. If you export ITAR tech data, you must tell the recipient the tech data is ITAR controlled by marking the tech data or cover letter. Third Answer: Assuming you are doing this in the US, the
