When a Special License May Be Required to Export a Vehicle From the United States

Normally a special export license is not needed to export an ordinary vehicle to most countries. However there are situations when a license is required where special circumstances exist. These circumstances usually fall under the umbrella of an embargo, sanction, and/or items included on what is known as the US Munitions Control List.

An embargo is enforced by the Bureau of Industry and Security, a branch of the US Department of Commerce. They maintain and enforce the export regulations of the United States along with the assistance of other key government agencies. Sanctions are enforced by the Office of Foreign Assets Control which is a branch of the US Treasury Department. The export of items on the US Munitions List fall under the International Traffic In Arms Regulation ( ITAR ) and is enforced by the Office of the Directorate Defense Trade Controls, a branch of the State Department.

For civilian vehicles, the technical level of armor protection along with their destination will usually determine whether or not a license will be needed either from BIS, OFAC or DDTC.

For this article we will limit our discussion to civilian privately owned vehicles modified with armor protection. Also some situations where an export license ay be required and by what federal agency. It is worth mentioning here that the majority of vehicle export shipments from the US to NATO listed countries are less restrictive.

The export from the United States of a car requiring a DDTC license is usually for one that has been modified with armor protection. If the modification has taken place here in the US, the company doing the modification may be able to advise you about the steps you can take to export your car. If the vehicle is being permanently exported for the first time from the US, a permanent export license ( DSP-5) may be required for export depending on the destination and/or protection level as established by the National Institute of Justice ( NIJ ). The US Munitions list( USML ) dated 4/1/13 under category X, paragraph (f), show the armor protection levels that do not need a DSP-5 license. Even though the paragraph refers to body armor, the protection levels apply to any article using this technology. However if exported to a non NATO listed country, a special Commerce Dept., license may be needed based on the destination and /or end user if a DDTC license is not required.

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