ITAR-06Edition 1.0 · November 2026
Managing Changes
Keeping ITAR authorizations current
A step-by-step method for non-US companies to spot changes to parties, scope, sites, people and dates, route each one to the right licence or agreement path, and implement it only when authorized.
What this guide settles
- Changes to the scope of an approved agreement take effect only after DDTC approval; minor amendments need no prior approval, apply once executed, and go to DDTC within 30 days
- A DSP-5 cannot be amended for more quantity, another commodity, destination, end use, end user or consignee, or a longer duration: a new licence for the unshipped balance — or §123.9 once exported
- Ownership changes and transfers are major amendments unless DDTC authorizes a minor one; after a US merger, unlisted licences are invalid and unamended agreements may be
- Most gaps are timing problems: catch changes in project, HR, procurement and M&A processes, and plan the approval before go-live
What you get
- The guide: explanations, method, conditions and limits
- Worked examples: common changes and their licence and agreement routes, minor and major amendments, Expedited Execution, corporate events, who does what, an illustrative acquisition and ten pitfalls
- Tools printed in the guide: four templates and a readiness check
- Sources with section references and their verification date
- Revisions included for 12 months
Printed tools: T1 · Change notice and impact map · T2 · Route selection · T3 · Change data pack · T4 · Implementation record and authorization chain · Readiness check
Contents
- Before you start: scope and limits
- Why changes are the weak point
- The rule in one page
- Amendments and corporate events
- The method in six steps
- Templates T1 to T4
- Ten pitfalls
- Case study: an unmapped acquisition
- Readiness check
What it does not cover
- One-off moves outside the authorization
- Registration matters of the US company
- Classified programmes and §126.1 countries
Assumed knowledge. Knowing how to read a DSP-5, how a TAA or MLA works for a foreign party, and how provisos are tracked.
Sample pages





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Where it connects
Supplier Changes, Substitutions & Reclassification
Managing Changes amends the ITAR authorizations themselves; Supplier Changes, Substitutions & Reclassification identifies what a supplier change touches, under the EAR and the ITAR.
ITAR-05Managing ITAR Provisos
Managing ITAR Provisos runs the conditions of an approval; Managing Changes handles amendments to the authorization itself.
ITAR-02ITAR Reexports & Retransfers
Reexports & Retransfers covers a proposed transfer; Managing Changes covers changes to the authorised arrangement.
ITAR-03TAA for Foreign Parties
TAA for Foreign Parties maps the agreement as approved; Managing Changes keeps it current as the business moves.
Part of a collection
Managing Changes is one of the eight guides of ITAR: Licenses, Agreements & Transfers (Understand the Rules), available together at €390 instead of €89 each.