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If I’m selling my civil item to a foreign military, do I need an export license under ITAR from State?
You do not need an export license from DDTC if your item is not controlled on the USML. That remains true even if you are selling the item to a foreign military. The end-user does not determine export jurisdiction.
Directorate of Defense Trade Controls (DDTC), U.S. State Department
http://www.pmddtc.state.gov/
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