Monthly Archives: February 2019


Advisory Opinions Accepted Online Through DECCS

Following last year’s testing, the Department of State, Directorate of Defense Trade Controls (DDTC) has announced the release of their new Advisory Opinions application for DDTC’s cloud-based Defense Export Control and Compliance System (DECCS).

The new Advisory Opinions application covers the following ITAR requests:

  • 126.9(a) – Whether DDTC would likely grant approval for a particular defense article or service to a particular country.*
  • 126.9(c) – ITAR interpretation
  • 129.9 – Guidance on whether an activity constitutes brokering under Part 129.

*Note that in many cases, it is preferable to submit a DSP-5 technical data license for marketing a defense article rather than a General Correspondence Advisory Opinion request.  While the new application is intended improve the submission and review process, a DSP-5 can avoid the need for two separate submissions for the same activity. (See DDTC’s 2016 guidance on advisory opinions.)

Other General Correspondence requests, such as §123.9 reexports or retransfers are still submitted in hard copy by mail.

The new application can be found at the DECCS Industry Service Portal:

See the DDTC News & Events page (02/04/2019) for more information on this release.

Comment on Commodity Jurisdiction Form

In related DECCS news, on February 6, 2019, DDTC published a notice (84 FR 2295) requesting comments on the DS-4076 Request for Commodity Jurisdiction Determination form.  This request is part of the Office of Management and Budget (OMB) approval process.

Comments may be submitted until April 8, 2019.  Please see the Federal Register Notice for additional details.

Comment on DDTC Registration Form

On February 13, 2019, DDTC published a notice (84 FR 3846) requesting comments on the DS-2032 Statement of Registration form.  This request is also part of the OMB approval process.  Notably, DDTC plans to remove the fields for Social Security Numbers and home addresses for the various senior officers listed on the form.

Comments may be submitted until March 15, 2019.  Please see the Federal Register Notice for additional details.