How does the See-Through Rule apply to PEI-Genesis products?
PEI-Genesis builds most connectors from component parts. If a component is identified as ITAR controlled by our supplier, then any and all products in which this component could be used is considered to be ITAR controlled and we will invoke the ITAR control processes in our Export Control Manual. This conforms to the current “strict” interpretation of the ITAR that is currently being used by the DDTC. For example: A connector is specifically designed for a US missile program. That connector incorporates a unique insulator contact pattern (layout). We stock the insulator and we can build dozens of different connectors using that insulator. PEI will use the see-through rule and tag all parent items that potentially use this insulator as ITAR controlled, even if the specific finished connector was never used in the original missile system. The intent of the DDTC is to prevent products containing controlled components from being reworked after the sale and having those components illegally
