Defense contractors and their suppliers accumulate inventory that cannot be thrown away.
Superseded parts, rejected production runs, test articles, obsolete tooling, marked packaging,
and printed technical data all pile up, and every one of them carries an export control question
that an ordinary waste hauler is not equipped to answer.
The stakes are different here than in commercial destruction. A mishandled pallet of consumer
goods is a brand problem. A mishandled pallet of controlled parts is a potential export violation,
and the penalties attached to export control failures are severe. This guide covers what actually
has to be controlled and what to ask a facility before anything moves.
There Is No Such Thing as an ITAR Certified Facility
This is worth stating plainly, because the term appears constantly in vendor marketing. The
United States government does not run an ITAR certification program. There is no audit, no
certificate, and no badge to earn. What exists is a registration requirement and an ongoing
compliance obligation.
Companies that manufacture defense articles, export them, furnish defense services, or broker
them are required to register with the Directorate of Defense Trade Controls at the State
Department. Registration is annual, and it involves a corporate officer attesting that the
company understands its obligations and has an export compliance program with a designated
Empowered Official in place.
Registration is the starting line, not the finish. It does not confirm that a company understands
the rules or follows them day to day. When a prime contractor sends a supplier questionnaire
asking you to certify ITAR compliance, what they actually want to know is whether you are
registered, whether you have a written compliance program, and whether you control who can
access controlled technical data inside your building.
So when a destruction vendor advertises itself as ITAR certified, that phrase by itself tells you
nothing. Ask what sits behind it.
What to Ask Before You Send Anything
• Are you registered with DDTC, and can you provide your registration status
• Do you have a written export compliance program and a designated Empowered Official
• Are all personnel with access to the material US persons under the applicable definition
• How is physical access to the processing area controlled and logged
• How is the material secured between receipt and destruction
• What does your destruction record state, and will it identify parts and quantities
specifically
• Can you accommodate a customer witness or a recorded destruction
A facility that cannot answer these quickly is telling you something useful. Confirm the
requirements that apply to your specific material with your Empowered Official or export counsel
before scheduling, because the answer depends on what the item is and where it sits on the
United States Munitions List.
What Has to Be Controlled During Destruction
Access by US Persons Only
Releasing controlled technical data to a foreign person inside the United States is treated as an
export. That principle does not pause because the item is on its way to a shredder. Anyone with
access to the material or to the drawings, markings, and part numbers on it is inside the control
boundary, including temporary labor and subcontracted drivers.
Technical Data Carried on the Item Itself
The part is often not the sensitive thing. The sensitive thing is what the part reveals: geometry,
tolerances, material specification, part numbers that map to a program, firmware on a board, or
a serial that ties to a contract. Destruction has to eliminate that information, not just render the
item unusable.
Physical Security and Chain of Custody
Sealed transport with recorded seal numbers, access-controlled receiving, and a documented
handoff at every transfer point. The gap between pickup and processing is where control is most
often lost, and it is also the gap nobody documents unless the vendor does it as a matter of
routine.
What Counts as Destroyed for a Defense Article
Disposal is not the standard here. The objective is to eliminate the functional capability and the
inherent design features of the item, so that it cannot be used for its original purpose and cannot
be reverse engineered from what remains. Methods range from removing and destroying
specific critical features through to total destruction by cutting, crushing, shredding, melting, or
burning.
For some categories the standard is mutilation to the point of scrap, meaning what leaves the
facility is raw material and nothing else. Partial damage is not sufficient where the design
information survives, and a damaged but recognizable component is still a source of intelligence
to anyone who recovers it.
The process also carries a verification expectation. Someone technically qualified is expected to
confirm that the destruction actually met the required degree, rather than simply attesting that
material was processed.
If You Hold Department of Defense Property, Check the DEMIL Code
Items in the Department of Defense supply system carry a demilitarization code that travels with
the national stock number and states the degree of physical destruction required before the item
can leave government control. The code is assigned during provisioning, not at end of life.
The codes escalate. Code A covers items requiring no demilitarization, though trade security
controls may still apply. Code B covers Munitions List items requiring mutilation to the point of
scrap worldwide. Code C requires removal and demilitarization of specified key points. Codes
above that carry further requirements, with separate handling for classified property and for
items controlled under the Commerce Control List.
The trap is assuming that obsolete means releasable. An item described as obsolete or as
formerly on the Munitions List can still carry a code requiring mutilation to scrap. Check the code
rather than the description.
Material That Comes Up Most Often
• Superseded and obsolete parts held against contracts that have ended
• Rejected production, nonconforming lots, and first articles
• Prototypes, test articles, and engineering samples
• Tooling, fixtures, and jigs that encode part geometry
• Printed drawings, specifications, and marked packaging
• Circuit boards, storage media, and devices holding firmware or configuration data
Documentation to Retain
The destruction record should identify parts by part number and quantity rather than by weight
alone, state the method and the degree of destruction achieved, name the date, location, and
facility, and be signed by an authorized person. Where a witness attended, the attestation
attaches to it.
File it with your export compliance records, not in a general operations folder. If a compliance
review ever reaches back to ask what happened to a particular lot, that record is the answer,
and it needs to be findable years later.
Destroy Controlled Inventory With a Record That Holds Up
At inventorydestruction.com, controlled and sensitive inventory is handled with secure chain of
custody, access-controlled processing, destruction to a specified degree rather than general
disposal, and a Certificate of Destruction issued on every project.
Confirm the requirements that apply to your material with your Empowered Official or export
counsel before scheduling. Contact our team today to arrange certified destruction with
complete documentation across all 50 states.
