AS9100 requires compliance with applicable regulatory and statutory requirements. ITAR (22 C.F.R.Chapter I, Subchapter M Parts 120-130) is a regulation covering either the manufacturing, exporting of defense articles or providing a defense service of articles listed on the United States Munitions List (USML). And yes, the ITAR has its own specific requirements for registration (122.2) and record-keeping (122.5).
For Example:
§122.1 (a) Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with the DDTC. For the purposes of this subchapter, engaging in the business of manufacturing or exporting defense articles or furnishing defense services requires only ONE OCCASION of MANUFACTURING or exporting a defense article or furnishing a defense service. Manufacturers who DO NOT engage in exporting MUST NEVERTHELESS register.
ITAR is easily worked around. All you have to do is show your product is an already established or variation of commercial product. It can be quite painful to follow ITAR, it even covers down to the ethnicity of the person driving the truck that delivers the final product and what roads he or she can travel....
The procedure you are referring is 120.4 Commodity Jurisdiction. Yes you can self designate, but you had better be correct! It is easier to simply request the DDTC to provide a "CJ" in writing for the defense article in question. The DDTC takes into account the number, variety and predominance of civil applications, the nature, function and capability of the civil applications and the nature, function and capability of the military applications.
Take care and don't confuse Dual-Use vs. USML. Per 120.3 it is ITAR Controlled if: Is specifically designed, developed, configured, adapted, or modified for military application,...
If the part was originally designed for a civil application, i.e. a fastener for a commercial aircraft and then used in a military aircraft (without modification), then it is considered Dual-Use and ITAR does not apply.
