# ITAR and Government Regulations for Aerospace Suppliers

> Precision Advanced Manufacturing breaks down ITAR, FAR, DFARS and FAA rules for aerospace suppliers. Get a practical compliance checklist.

**Published:** 2026-03-24 | **Updated:** 2026-10-31 | **Author:** precision
**URL:** https://precisionam.com/articles/aerospace/itar-regulations-aerospace-parts-manufacturers/
**Type:** post

**Categories:** Aerospace

![ITAR and Government Regulations for Aerospace Suppliers](https://blog.precisionam.com/wp-content/uploads/sites/56/2026/03/1774278103903-a5d6702e79b5-1024x572.jpeg)

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## Content

*Last updated: October 29, 2026*

## Key Takeaways

- ITAR registration is mandatory for any U.S. manufacturer producing defense articles on the USML, even without exporting, and no separate “ITAR certification” exists.
- Jurisdiction is determined by a part’s technical characteristics against the USML. Uncertain classifications require a DDTC Commodity Jurisdiction request.
- Compliance relies on a designated Empowered Official, a documented Technology Control Plan, foreign-person screening and controlled access to technical data.
- FAR/DFARS flow-down, FAA production approvals (PC, PMA, TSOA) and AS9100D certification are distinct obligations that are verified separately from ITAR registration.
- Precision Advanced Manufacturing is an ITAR-registered, AS9100D and ISO 9001:2015 certified U.S. manufacturer that supports aerospace and defense programs with full compliance documentation and traceability.

[Discuss an ITAR-Controlled Program With Precision Advanced Manufacturing](https://precisionam.com/request-a-quote/?utm_term=itar-regulations-aerospace-parts-manufacturers&utm_campaign=ai_growth_agent)

## ITAR Fundamentals for Aerospace Parts Manufacturers

Many aerospace suppliers describe themselves as “ITAR certified,” but ITAR provides registration, not certification. Under [22 CFR 120.13(a)](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-B/section-120.13), any person that manufactures defense articles in the United States must register with DDTC under Part 122, even without exporting. [A single occasion of manufacturing a defense article](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-B/section-120.13) triggers this obligation.

[USML Category VIII covers aircraft and related articles](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-121/subject-group-ECFRf7e5fe639be4566). [Category XIX covers certain propulsion and related articles, including rocket and missile engines cross-referenced from Category IV](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-121/subject-group-ECFRf7e5fe639be4566). Classification within these categories depends on the part’s technical characteristics and the applicable USML paragraph. Under [22 CFR 120.11(c)](https://ecfr.gov/current/title-22/section-120.11), a defense article described on the USML remains ITAR controlled after incorporation into an uncontrolled assembly.

The deemed-export rule is a critical shop-floor risk. Under [22 CFR 120.50(a)(2)](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-C/section-120.50), releasing technical data to a foreign person in the United States constitutes an export. Under [22 CFR 120.50(b)](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-C/section-120.50), that release is deemed an export to every country where that person holds citizenship or permanent residency. Shop-floor access by a foreign national to ITAR-controlled drawings or CAM files can create multiple simultaneous exports.

The Empowered Official role, defined at [22 CFR 120.67](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-C/section-120.67), belongs to a U.S. person directly employed by the registrant. That person holds written legal authority to sign license applications and independent authority to refuse any application. The Technology Control Plan (TCP) is the operational document that governs how controlled technical data is stored, accessed and protected across the facility.

### Three Core Actions Required for ITAR Compliance

1. Register with DDTC under 22 CFR Part 122 and formally designate an Empowered Official with written authority and independent signing power.
2. Classify parts against the USML and control related technical data under a documented Technology Control Plan that governs access, storage and transmission.
3. Screen personnel and visitors for foreign-person status, restrict access to controlled technical data to U.S. persons or license-authorized individuals and maintain export training records.

## The Jurisdiction Decision: USML vs EAR vs 600-Series

Manufacturing for a defense customer does not automatically make a part ITAR controlled. Under [22 CFR 120.3](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-A/section-120.3), the intended use of an article after export is not, by itself, a factor in determining ITAR applicability. Jurisdiction follows the item’s technical characteristics and its match to a USML entry.

Classification begins with the [order of review at 22 CFR 120.11](https://ecfr.gov/current/title-22/section-120.11). First, review the item’s general characteristics to identify the appropriate USML category. Then match its specific characteristics and functions to a paragraph within that category. If the entry uses “specially designed,” [consult 22 CFR 120.41 for exclusions](https://ecfr.gov/current/title-22/section-120.11). [An item described in multiple USML entries is categorized under the enumerated entry](https://ecfr.gov/current/title-22/section-120.11) rather than a catch-all paragraph.

Items not on the USML may fall under the [Commerce Control List (CCL) at 15 CFR Part 774](http://ecfr.gov/current/title-15/part-774), administered by BIS. The CCL assigns Export Control Classification Numbers (ECCNs) to controlled items. Items not described by any ECCN may be EAR99, which still subjects them to end-use, end-user and destination restrictions. [The 600-series ECCNs cover military items that have moved from USML to Commerce jurisdiction](http://ecfr.gov/current/title-15/part-774), so a part that was once ITAR controlled may now fall under a 600-series entry.

When jurisdiction is uncertain, a manufacturer submits [Form DS-4076 to DDTC for a Commodity Jurisdiction determination under 22 CFR 120.12](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-B/section-120.12). [DDTC provides a preliminary response within 10 working days](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-B/section-120.12). [If no final determination issues after 45 days, the applicant may request expedited processing in writing](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-B/section-120.12). [DDTC registration is not required to submit a CJ request](https://ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-B/section-120.12).

ITAR, EAR and AS9100D address different needs. ITAR governs defense articles and services. EAR governs dual-use items under Commerce jurisdiction. AS9100D governs quality management. A supplier may hold AS9100D certification while lacking ITAR registration, and ITAR registration does not satisfy EAR classification obligations.

## FAR and DFARS Flow-Down for Aerospace Suppliers

Once jurisdiction is settled, the next layer of obligation arrives through the contract. FAR and DFARS clauses flow from a prime contract through purchase orders to subcontractors. A parts manufacturer must identify which clauses its purchase orders carry and what obligations those clauses impose at the shop level.

DFARS 252.204-7012 requires contractors to provide adequate security on covered contractor information systems by implementing the controls in NIST SP 800-171. It also requires contractors to report cyber incidents to DoD within 72 hours of discovery. The clause flows to subcontractors when performance involves covered defense information. A machine shop that stores, processes or transmits controlled technical information tied to a defense contract is likely within scope.

DFARS 252.225-7009 addresses specialty metals. [DFARS 252.225-7009(b) requires specialty metals in delivered items to be melted or produced in the United States, its outlying areas or a qualifying country](https://www.ecfr.gov/current/title-48/chapter-2/subchapter-H/part-252/subpart-252.2/section-252.225-7009). Paragraph (c) lists exceptions, including electronic components, COTS items, items manufactured in a qualifying country and minimal amounts of noncompliant metals. Aerospace parts manufacturers working with titanium, steel or other specialty metals on defense programs must verify their material supply chain against this requirement.

Counterfeit-part prevention appears in [DFARS 252.246-7007](https://ecfr.gov/current/title-48/chapter-2/subchapter-H/part-252/subpart-252.2/section-252.246-7007), which requires a risk-based counterfeit electronic part detection and avoidance system. That system covers training, inspection, traceability, supplier controls and GIDEP reporting. [DFARS 252.246-7008 governs approved sources for electronic parts](https://ecfr.gov/current/title-48/section-246.870-3). These clauses flow to subcontractors at all levels when electronic parts are involved.

Because clauses vary by contract, buyers confirm applicable clauses and current self-assessment status with each supplier independently. That confirmation starts with evidence of a purchase-order review process, a clause-identification procedure and documented flow-down to lower-tier subcontractors.

## FAA Production Approvals for Aerospace Parts

FAA production approvals form another layer of oversight, separate from ITAR registration and AS9100D certification. A supplier may hold one or more approvals depending on the parts produced and the programs supported.

A [Production Certificate (PC), governed by 14 CFR Part 21 Subpart G](http://ecfr.gov/current/title-14/part-21/subpart-G), authorizes a manufacturer to produce complete products under an FAA-approved type design. The PC holder must own or have licensed rights to the type certificate and must [maintain a quality system meeting the 15 elements in 14 CFR 21.137](http://ecfr.gov/current/title-14/part-21/subpart-G). [The PC is not transferable and covers only the products listed in the production limitation record](http://ecfr.gov/current/title-14/part-21/subpart-G).

A Parts Manufacturer Approval (PMA) authorizes a manufacturer to produce replacement or modification parts for type-certificated products without holding the original type certificate. PMA fits a machine shop that produces FAA-approved replacement parts for civil aircraft.

A [Technical Standard Order Authorization (TSOA), governed by 14 CFR Part 21 Subpart O](https://ecfr.gov/current/title-14/chapter-I/subchapter-C/part-21/subpart-O), is an FAA design and production approval for articles that meet a specific TSO minimum performance standard, such as certain avionics or emergency equipment. [Under 14 CFR 21.601(b)(5), the TSOA holder remains accountable for supplier-produced content](https://ecfr.gov/current/title-14/chapter-I/subchapter-C/part-21/subpart-O) because the holder controls the design and quality of the article, including procured parts.

A buyer verifying FAA production approval confirms the approval type, approval number, the specific articles or products covered and the relationship between the approval holder and any subcontract machine shop.

## AS9100D as the Quality Backbone

AS9100D provides the quality management framework that supports aerospace and defense compliance. [AS9100D is built on ISO 9001:2015 and adds aviation, space and defense requirements](https://hgint.com/wp-content/uploads/2026/10/AS9100D_Audit_Readiness_Guide_and_Gap_Analysis.pdf). These include configuration management (8.1.2), operational risk management (8.1.1), product safety (8.1.3), counterfeit-part prevention (8.1.4) and expanded identification and traceability (8.5.2).

ITAR governs who may access technical data and under what conditions. DFARS governs contract flow-down and cybersecurity obligations. AS9100D governs the quality management system that produces inspection records, material certifications, nonconformance reports and corrective actions that buyers use to verify compliance with both.

An AS9100D certificate’s scope statement defines the products, services and sites covered by the registration. A buyer reads the scope statement carefully, because a certificate covering “precision machined components” at a specific facility does not automatically cover fabrication, welding or finishing at a different location. The issuing certification body and the certificate’s current validity are confirmed through the IAQG OASIS database.

AS9100D certification does not serve as evidence of ITAR compliance, NIST SP 800-171 implementation or FAA production approval. These obligations remain separate and require their own verification.

## How to Verify a Supplier’s Compliance: A Buyer’s Checklist

Because ITAR, DFARS and AS9100D are verified separately, pre-award verification works best as a document review across all three. The checklist below shows what to request and what each item supports.

- DDTC registration confirmation and current registration status, including the named Empowered Official and written designation
- Technology Control Plan, including access-control procedures, visitor log policies and foreign-national screening records
- AS9100D certificate with scope statement, issuing certification body and expiration date, verified against IAQG OASIS
- ISO 9001:2015 registration, if applicable
- Material certifications and certificates of conformance for materials used in controlled programs
- Inspection reports and first-article inspection records that demonstrate dimensional and specification compliance
- Purchase-order flow-down review process, including evidence that DFARS clauses are identified and passed to lower-tier suppliers
- Export training records for personnel with access to controlled technical data
- Counterfeit-part avoidance procedures when electronic parts are involved

During a site audit, a supplier quality engineer asks how the supplier identifies foreign nationals on the shop floor and how controlled drawings and CAM files are stored and access restricted. The engineer also reviews how visitor access to controlled areas is logged and how the supplier handles requests from foreign nationals for ITAR-controlled technical data.

## Common Violations and How to Avoid Them

Uncontrolled technical data ranks among the most frequent ITAR violations in the aerospace supply chain. Controlled drawings, CAD files and CAM programs stored on shared drives without access restrictions, emailed without authorization review or accessible to foreign nationals without a license constitute deemed exports. A documented TCP with access controls enforced at the file, network and physical levels addresses this risk.

Unauthorized foreign-national access occurs when a supplier lacks a formal screening process or when access controls are not enforced consistently on the shop floor. A written access-control policy, a visitor log and personnel training that covers the deemed-export rule reduce this exposure.

Inadequate recordkeeping, such as missing export training logs, unsigned TCPs or undocumented Empowered Official designations, leaves a supplier unable to demonstrate compliance during an audit or investigation. A records-retention schedule tied to the TCP and integrated into the AS9100D quality management system closes these gaps.

For a deeper review of common violations and their operational remedies, see [Common ITAR Violations in the Aerospace Supply Chain](https://precisionam.com/articles/common-itar-violations-aerospace-manufacturing/?utm_term=itar-regulations-aerospace-parts-manufacturers&utm_campaign=ai_growth_agent).

## Precision Advanced Manufacturing: A Verifiable ITAR-Registered Aerospace Partner

Precision Advanced Manufacturing is an ITAR-registered, AS9100D and ISO 9001:2015 certified U.S. manufacturer of high-precision machined and fabricated components. Programs include commercial aerospace, military and defense, space and satellites, advanced industrials and UAV platforms. The company operates under NAICS codes 332710 (Machine Shops) and 332721 (Precision Turned Product Manufacturing) across two U.S. locations that support made-in-America manufacturing.

![A commercial airliner in flight against a blue sky.](https://cdn.aigrowthmarketer.co/1785164215115-cf050b902241.webp)**Aerospace manufacturing for flight-critical hardware, with machining and fabrication supported by AS9100D quality management and traceability practices.**

Capabilities include multi-axis CNC milling and turning, Swiss-type machining and machining of titanium and Inconel. Precision sheet metal fabrication, specialty and laser welding with thermal-distortion control, kitting, hardware installation, deburring, brush finishing and laser marking are supported in-house. Secondary finishing, including anodizing, passivation and plating, is available to aerospace standards.

![A satellite orbiting above the Earth.](https://cdn.aigrowthmarketer.co/1785164232174-7d0cbe7ee84c.webp)**Space-grade components demand dependable performance. Precision machining and controlled manufacturing processes support the reliability requirements of satellite and launch applications.**

Precision Advanced Manufacturing’s certified quality systems align with the buyer checklist above. ITAR registration and a named Empowered Official are verifiable through DDTC. AS9100D and ISO 9001:2015 registrations are verifiable through the issuing certification body. Full documentation and traceability, inspection reporting and material certifications are produced for every program, which reduces the inspection burden on customer quality teams and supports audit readiness.

![A CMM touch probe measuring a machined aluminum bracket.](https://cdn.aigrowthmarketer.co/1785164194032-a09872ce26c4.webp)**CMM inspection and controlled quality workflows verify critical dimensions, supporting first-article and in-process inspection with traceable measurement data.**

Programs can progress from prototype through full-rate production with multi-shift capacity. Supplier transitions are supported with complete documentation, material traceability and validation runs that help manage program risk.

For additional guidance on evaluating ITAR-registered suppliers, see [ITAR Compliant Aerospace Parts Suppliers: 2026 Guide](https://precisionam.com/articles/itar-compliant-aerospace-parts-suppliers/?utm_term=itar-regulations-aerospace-parts-manufacturers&utm_campaign=ai_growth_agent) and [ITAR Aerospace Manufacturer: A Supplier Evaluation Guide](https://precisionam.com/articles/itar-compliant-aerospace-manufacturers-usa/?utm_term=itar-regulations-aerospace-parts-manufacturers&utm_campaign=ai_growth_agent).

[Review Compliance Documentation With Our Team](https://precisionam.com/request-a-quote/?utm_term=itar-regulations-aerospace-parts-manufacturers&utm_campaign=ai_growth_agent)

## Frequently Asked Questions

### Who Needs to Be ITAR Compliant?

Any person or company that manufactures, exports or temporarily imports defense articles, or furnishes defense services, must register with DDTC under 22 CFR Part 122. This group includes machine shops that produce USML-controlled parts even if they never export. Subcontractors that receive controlled technical data from a prime also fall under ITAR obligations.

### What Parts Are Subject to ITAR?

Parts fall under ITAR when they are enumerated in a USML category or described in a catch-all paragraph using “specially designed” as a control criterion. USML Categories VIII and XIX cover aircraft, spacecraft and related propulsion articles. Classification is based on the part’s technical characteristics.

### Who Is Considered a U.S. Person Under ITAR?

[Under 22 CFR 120.62, a U.S. person means a lawful permanent resident as defined by 8 U.S.C. 1101(a)(20) or a protected individual as defined by 8 U.S.C. 1324b(a)(3), and also includes any corporation, business association, partnership, society, trust or other entity incorporated to do business in the United States, as well as any governmental (federal, state or local) entity](https://www.ecfr.gov/current/title-22/chapter-I/subchapter-M/part-120/subpart-C/section-120.62). Foreign nationals, regardless of location, are not U.S. persons, and providing them access to controlled technical data constitutes a deemed export under 22 CFR 120.50.

### Do Manufacturers Need an ITAR License or an ITAR Certification?

As noted above, manufacturers register with DDTC; no separate certification exists. Licenses or other DDTC approvals are required before exporting, reexporting or retransferring a defense article or furnishing a defense service, unless an exemption applies. [Registration and licensing are distinct obligations under 22 CFR Parts 122 and 123](https://jdmachine.com/news/defense-machining-itar-cmmc-as9100-vetting).

### What Is the Difference Between ITAR and EAR for Aerospace Parts?

ITAR, administered by the State Department’s DDTC, controls defense articles and services on the USML. EAR, administered by Commerce’s BIS, controls dual-use items on the Commerce Control List, including 600-series military items that have moved from USML jurisdiction. A part’s jurisdiction is determined by its technical characteristics and the applicable regulatory list.

### How Does a Buyer Verify a Supplier’s ITAR Compliance?

Verification relies on document-level evidence such as DDTC registration status, a written Empowered Official designation, a current Technology Control Plan, access-control and visitor logs, export training records and an AS9100D certificate with scope confirmed through IAQG OASIS. Registration alone does not demonstrate operational compliance, so the TCP and access-control records carry significant audit weight.

## Conclusion and Next Steps

The regulatory stack governing aerospace parts manufacturing functions as a connected system. It includes ITAR, EAR, FAR and DFARS flow-down, FAA production approvals and AS9100D. Jurisdiction comes first. Teams classify the part, identify which regimes apply and then verify the supplier against documented evidence.

Practical next steps for procurement and supplier quality teams include confirming part jurisdiction through USML review or a DDTC CJ determination and reviewing purchase-order flow-down clauses for applicable DFARS requirements. Teams then request the supplier’s compliance documentation against the checklist above and schedule a site audit focused on foreign-national access controls, technical-data handling and export training records.

Precision Advanced Manufacturing’s aerospace and defense specialists are available to review program needs, part specifications and compliance requirements and provide a tailored quote.

[Start a Program Review With Precision Advanced Manufacturing](https://precisionam.com/request-a-quote/?utm_term=itar-regulations-aerospace-parts-manufacturers&utm_campaign=ai_growth_agent)

## What to Read Next

- [ITAR Compliant Aerospace Parts Suppliers: 2026 Guide](https://precisionam.com/articles/itar-compliant-aerospace-parts-suppliers/)
- [ITAR Compliant Manufacturing for Aerospace: A Buyer’s Guide](https://precisionam.com/articles/itar-compliant-manufacturing-aerospace-suppliers/)
- [ITAR Aerospace Parts Manufacturers: Buyer Verification Guide](https://precisionam.com/articles/itar-compliant-us-aerospace-manufacturers/)
- [ITAR Aerospace Manufacturer: A Supplier Evaluation Guide](https://precisionam.com/articles/itar-compliant-aerospace-manufacturers-usa/)
- [ITAR Compliance for Aerospace Machining Suppliers](https://precisionam.com/articles/itar-compliant-machining-requirements-aerospace/)

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---

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## Citations

- [Leading Aerospace Manufacturers in the US for Complex Parts](https://precisionam.com/articles/aerospace/best-aerospace-machining-companies-us/)
- [Aerospace Parts Full Traceability: A Document Package Guide](https://precisionam.com/articles/aerospace/aerospace-parts-traceability-requirements/)
- [Aerospace Machining Tolerances: Standards and GD&amp;T](https://precisionam.com/articles/aerospace/aerospace-component-manufacturing-tolerances/)
- [Space Qualified CNC Machining: What Flight Hardware Requires](https://precisionam.com/articles/aerospace/space-qualified-cnc-machining-guide/)
- [ITAR CNC Machining for Military Aircraft: A Supplier Guide](https://precisionam.com/articles/aerospace/itar-cnc-machining-military-aircraft/)

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