DDTC Issues ITAR Guidance on 'See-Through Rule'

The State Department’s Directorate of Defense Trade Controls issued guidance Oct. 5 on the “see-through rule” -- a “colloquial phrase” that refers to the impact of controls under International Traffic in Arms Regulations. DDTC clarified the rule by stressing that ITAR controls and requirements do not “disappear simply because the defense article is integrated into another item.” If an ITAR-controlled component is integrated into a “larger system or end-item,” the component does “not lose its identity.” DDTC said “the ITAR ‘sees through’ the larger system or end-item and continues to regulate that defense article.”