International Law Advisory - D-Trade Becomes Mandatory Starting January 31

On December 14, 2006, the Directorate of Defense Trade Controls (DDTC) posted a notice on their website indicating that on our about January 31, 2007, it will no longer be accepting hard copy export license applications, except for in instances where an exception to the registration requirement is being requested.  As of January 31, the following application forms, which include the new D-Trade Amendment forms, will only be accepted via D-Trade, DDTC's electronic filing system

• DSP-5 Application for the Permanent Export of Unclassified Defense Articles and Related Unclassified Technical Data
• DSP-6 DSP-5 Amendment
• DSP-61 Application for the Temporary Import of Unclassified Defense Articles
• DSP-62 DSP-61 Amendment
• DSP-73 Application for the Temporary Export of Unclassified Defense Articles
• DSP-74 DSP-73 Amendment

The ELLIE system, which allowed the submission of the DSP-119 Amendment form, will also be discontinued.  Any DSP-119 Amendment applications received after January 31 will not be processed. Applicants will be required to use the new D-Trade DSP-6, DSP-62 or DSP-74 form.

Submissions NOT affected by this coming change include: DSP-85 (Application/License for Permanent/Temporary Export or Temporary Import of Classified Defense Articles and Classified Technical Data), General Correspondences (GCs), Agreements/Amendments (AGs; TAAs; MAs), and Brokering Requests (BAs).

Companies can learn more about D-Trade on DDTC's D-Trade Information Center website, which is available here.  Should you have any additional questions regarding the electronic submission process at DDTC, or about ITAR licensing generally, please contact Ed Krauland at (202) 429-8083 or Andy Irwin at 202 429 8177.