October 15th, 2012
When your organization is requested to participate in an export transaction, it is your responsibility to ensure that all parties to the transaction are eligible to engage in exporting. This includes identifying all organizations involved in the manufacturing processm including minor components and parts. So when completing a DSP-5 application, pay close attention to Block 15 Manufacturer of Commodity. According to the DDTC the applicant must seek to determine when the source of the commodity is a manufacturer, that the manufacturer is registered with the DDTC, and also listing all sub-tier manufacturing suppliers, including special process suppliers.
Let’s look at another side of this scenario: Your customer is going to export a USML item (not SME) and your company performs the Nondestructive Testing and preparing the Test Report which will contain Technical Data. The concern is, since you know they are going to export the parts and technical data, should you ask to confirm your company is listed as one of the companies on Block 15? The answer is: absolutely yes. Without having positive evidence of a properly issued DSP-5 License listing both your company as the NDT service provider and the technical data created, you should not proceed (See 127.1 Violations).