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by mothballed
269 days ago
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I'm no ITAR expert either, but IDK how wearing a T-shirt could possibly be an export. My lay understanding of export is that the information would somehow have to leave the country; if someone looks at the T-shirt and transmits it out the country they'd be the exporter, not the person wearing the T-shirt. If someone records the t-shirt and transmits it, they'd be the exporter. |
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It's not just physical items like munitions, but also things like transfers of information (blueprints, technical data, documentation, etc.) or services being performed, regardless of where (inside or outside the USA) or how (paper, electronic, verbal, etc.) it takes place.
Have a look at [1] § 120.50 (Export) and § 120.63 (definition of Foreign person).
>if someone looks at the T-shirt and transmits it out the country they'd be the exporter, not the person wearing the T-shirt.
I believe the person wearing the shirt would be considered the exporter, as that is the point where the information moves from (I'm assuming for the purposes of conversation) an USA citizen to a foreign person.
But again, I could be wrong. Safest bet is not to print the shirt to begin with :)
[1] https://www.ecfr.gov/current/title-22/chapter-I/subchapter-M...