As a global leader in ballistics and ballistic resistance testing, HP White serves clients from around the world. When conducting tests for clients outside of the United States, the resulting data and test reports are considered exports. HP White must comply with all US Government-mandated export regulations. For certain types of testing, an export license must be obtained before test results can be exported. Below is a brief primer to help guide clients through the US International Traffic in Arms Regulations (ITAR) Licensing process.
Some of the key forms and processes covered include,
- ITAR Information Form: Enables HP White to submit licensing applications for approval;
- ITAR Letter of Assurance: Client’s acceptance of ITAR terms;
- DSP 61 Licensing: Allows export of test samples back to client (if needed) once testing is completed; and
- DSP 5 Licensing: Allows the export of test data once testing is completed.
ITAR License Requirements
All items that fall on the USML require DSP-5 Licensing; and all corresponding testing requires completion of a Letter of Assurance. If tested items are to be returned after testing, a DSP-61 License must also be obtained.
Requesting sample return after testing may delay testing by a minimum of 2–4 weeks. If samples are to be destroyed after testing, samples can be sent and tested without delay.
If the testing being requested is expected to be conducted on a recurring basis, it may be appropriate to apply for a long-term license under a Technical Assistance Agreement (TAA). Establishing a TAA requires more effort initially, but can save a considerable amount of time in the long run. For more information related to TAA’s, please contact HP White directly.
The DSP-61 License requirement applies only to samples that will be returned after testing. A DSP-61 License must be obtained prior to shipping samples to HP White. The DSP-61 License allows temporary import and post-test export of an item listed on the USML.
The process is as follows:
- Client submits an ITAR Information Form and Letter of Assurance to HP White
- HP White submits a DSP-61 Application to DDTC
- DDTC reviews DSP-61 Application and will:
- Accept the Application and issue a License (Testing may proceed)
- Reject the Application (Testing cannot proceed)
- Request additional information (The ITAR Information Form should include as much detail as possible to limit the risk of requests for additional information, which can delay testing for an additional 2 – 4 weeks).
Letter of Assurance:
The Letter of Assurance applies to all test projects. A Letter of Assurance must be signed and returned to HP White upon acceptance of a Quote from HP White. The Letter of Assurance can be found within the ITAR Information Form.
A DSP-5 License must be obtained from DDTC for all ITAR-related projects. The ITAR Information Form must be completed and returned upon acceptance of a Quote from HP White.
The process is as follows:
- Client submits the ITAR Information Form and Letter of Assurance to HP White
- Client ships samples to HP White for testing
- HP White initiates testing of samples upon receipt. After testing is completed, HP White submits the DSP-5 application to the DDTC. Pass/Fail information can be provided to the client.
- DDTC reviews the DSP-5 Form and will:
- Accept the Application and issue a License (A full Test Report can be given to the client)
- Request additional information (Applications should provide as much detail as possible to limit the risk of requests for additional information; which can delay testing for an additional 2 – 4 weeks).
- Reject the Application (A “SUMMARY REPORT” can be given to the client)
Notes: The “SUMMARY REPORT” does not include projectile velocities, backface signature, projectile specifications and other restricted data. It simply advises the client as to whether the samples Passed or Failed the client’s performance requirements. The client should define Pass/Fail criteria prior to the initiation of testing. In the case of an NIJ Compliance Test, the full Test Report will be provided to NLECTC.