Tuesday, July 29, 2008

Proposed Registration Fee Changes at DDTC

I wanted to take a moment to let you know that the State Department’s Directorate of Defense Trade Controls (DDTC) is proposing an increase in annual registration fees. The change creates a multi-tiered fee system. I have included the heart of the proposed change below for your review as this will impact some of you significantly:


“The first tier will be a set fee of $2,250 per year for registrants who are renewing a registration, required to register by law and who have not submitted any applications during the twelve month period ending 90 days prior to the expiration of their current registration. This tier includes those registering with the Department for the first time.

The second tier is for registrants who have submitted ten or fewer applications during the twelve month period ending 90 days prior to the expiration of their current registration. For this tier, registrants will pay a set fee of $2,750 per year.

The third tier is for registrants who have submitted more than ten applications during the twelve month period ending 90 days prior to the expiration of their current registration. For this tier, registrants will pay a fee of $2,750 plus an additional fee that is based on the number of applications they submitted during the twelve months ending 90 days prior to the expiration of their current registration. The additional fee will be determined by multiplying $250 times the number of applications over ten submitted during the twelve month period ending 90 days prior to the expiration of the current registration.”

This proposed change is going to require that your businesses track their application history to determine the volume of applications submitted. It is also going to create an added cost of $250 per license request over ten during any given year. While this is only a proposed change at this time, I recommend planning for this increase in your cost structure moving forward. If any of you would like more information about the proposed change please visit: http://edocket.access.gpo.gov/2008/E8-17232.htm . If your business has strong objections to the change it is possible to make your objections known. Please contact me directly if you have any questions.