SUP-07Edition 1.0 · November 2026
Buying Through Distributors & Resellers
Getting the evidence when the seller is not the manufacturer
A step-by-step method for non-US companies buying US-origin items through distributors, stockists, marketplaces or group purchasing — to decide which information to believe when it reaches them through several hands, and on what basis they receive and use the items.
What this guide settles
- An intermediary adds evidentiary distance; it does not change the regulatory question — the item stays what it is, and the seller is a relay unless it is the source
- A distributor holds whichever party role (§748.5) and movement role it holds in a given transaction; manufacturer-authorized is not export-authorized
- Every export-control event needs the correct regulatory basis, not necessarily a licence — and a broken chain is a diligence question, not proof of a violation
- Weigh by exact item match, distance and date; the STA reliance rule is specific, and a marketplace listing is a claim
What you get
- The guide: explanations, method, conditions and limits
- Worked examples: one item and its four lines (events, information, party and movement roles), four channel cases, information source by source, a weighing grid, red flags specific to indirect channels, the ITAR §123.9(a) rule, a composite case and ten pitfalls
- Tools printed in the guide: four templates, including a channel map and a source and relay matrix, and a readiness check
- Sources with section references and their verification date
- Revisions included for 12 months
Printed tools: T1 · Channel map · T2 · Source and relay matrix · T3 · Requests by actor · T4 · Receipt and decision record · Readiness check
Contents
- Before you start: scope and limits
- Why the channel matters
- The rule in one page
- Information through the channel
- The method in six steps
- Templates T1 to T4
- Ten pitfalls
- Case study: the listing and the sheet
- Readiness check
What it does not cover
- Due diligence on the intermediary itself, and diversion red flags
- Historical authorization that cannot be found at all
- ITAR brokering under Part 129
Assumed knowledge. How to request classification information from a manufacturer, and what a reexport and a transfer (in-country) are.
Sample pages





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Where it connects
Supplier Classification Requests
Requesting Export Classification Information asks the manufacturer directly; Buying Through Distributors & Resellers weighs what reaches you through several hands.
SUP-05Missing Licenses
Missing Licenses reconstructs a past that left no evidence; Buying Through Distributors & Resellers decides which information to believe when it exists but arrives through relays.
Part of a collection
Buying Through Distributors & Resellers is one of the eight guides of Suppliers & Procurement (Manage Transactions), available together at €390 instead of €89 each.