Air Combat Simulators & Parts

ITAR applicability depends on whether the simulator is specifically designed or modified for a defense article or incorporates controlled technology. Even simulators that replicate unclassified aircraft may be USML-controlled if they are designed to train in weapons employment or electronic warfare. A formal commodity jurisdiction determination from the State Department is advisable when the classification is uncertain.

Transaction value is the primary CBP valuation method, but government-to-government sales and cost-plus defense contracts can complicate standard valuation. Importers should retain all contract documentation, including any government furnished equipment (GFE) values, and may need to work with a customs broker experienced in defense procurement imports to ensure accurate declared value.