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Export compliance
Export compliance policy: what we accept and what we refuse
milcnc.com matches defense-adjacent CNC work with suppliers outside the United States, with a focus on Vietnam. That only works for drawings that are free to leave your country. This page sets out where we draw the line.
Decision table
Data types and our answer
| Technical data | Our answer | Why |
|---|---|---|
| ITAR / USML-controlled technical data | Refused | Needs US Department of State authorization to reach a foreign person. We do not accept it under any circumstances. |
| EAR 600-series or other ECCN-controlled technical data | Refused unless you hold the licence | Depending on the ECCN and destination, a Commerce licence may be needed. Send only if you hold it and state the licence in the RFQ. |
| EAR99 / not export-controlled | Accepted | The usual case for ground support, training, range, enclosure and bracket drawings. You still confirm the classification. |
| Controlled Unclassified Information (CUI) | Refused unless authorized | CUI marked data carries its own handling rules (DFARS 252.204-7012, NIST SP 800-171). Do not send CUI to offshore suppliers without authorization. |
| Classified information | Refused | Never send classified material through this site. |
Your part
Before you send a drawing
- Confirm the jurisdiction: ITAR (22 CFR 120 to 130, USML in part 121) or EAR (15 CFR 730 to 774).
- If EAR, find the ECCN on the Commerce Control List or confirm EAR99.
- Check whether the drawing carries CUI or distribution markings.
- Check the destination and end user against current sanctions and licence requirements.
- State the result in the RFQ form. If unsure, ask your export-compliance officer first.
Official sources: ITAR on eCFR and EAR on eCFR.
Our checks
What we do on every RFQ
- Require an export classification statement on the RFQ form
- Refuse any RFQ that mentions ITAR, USML or a controlled end item
- Screen the part against the out-of-scope list below
- Ask for end-use and end-user on dual-use items
- Share drawings only under NDA with up to 3 matched suppliers
- Delete files on request after the RFQ closes
Scope
Parts we match and parts we refuse
In scope
- Ground support equipment housings and brackets
- Training simulator hardware
- Range and target system components
- Tactical accessories (rails, mounts, non-firearm)
- Optics enclosures and camera housings
- Communications equipment chassis
- UAV and unmanned platform structural parts (not export-controlled)
- Field-deployed kit hardware
Out of scope
- Firearm components (receivers, barrels, fire control)
- Munitions, ordnance, explosives hardware
- Missile / rocket airframe structural parts
- Night vision optics / military-grade IR
- Encryption hardware
- Anything ITAR / USML controlled
- Anything Wassenaar dual-use restricted without a licence
- End-user-restricted destinations
FAQ
Export compliance questions
Who is responsible for the export classification of my part?
You are. The owner of the technical data knows its jurisdiction (ITAR or EAR) and classification (USML category, ECCN or EAR99). We ask for a statement of classification with every RFQ and refuse anything marked or described as ITAR-controlled, but we do not classify parts for you and do not give legal advice.
Can a controlled part be machined from an uncontrolled drawing?
Classification follows the item and the technical data, not the file format. A simple drawing of a part that is specially designed for a USML item can still be ITAR technical data. If the end item is on the USML, assume the drawing is controlled until your compliance officer confirms otherwise.
Is milcnc.com registered with DDTC?
No. milcnc.com is not registered with the US Directorate of Defense Trade Controls and holds no defense approval. That is one reason we refuse ITAR-controlled data.
Do you ship to any destination?
No. We do not match RFQs for end users or destinations restricted under US, EU or UN sanctions or Wassenaar controls. For dual-use end items we ask the buyer to confirm end-use and end-user before matching.
Drawing confirmed EAR99 or licensed?
Send it with the classification statement. We reply within 24 business hours.
Send RFQ