Aerospace Products & Parts

Aerospace articles frequently fall under the International Traffic in Arms Regulations (ITAR) administered by the State Department's Directorate of Defense Trade Controls, or the Export Administration Regulations (EAR) administered by the Commerce Department's Bureau of Industry and Security. The applicable framework depends on whether the item is defense-specific or dual-use; misclassification between the two carries significant legal risk.

CBP applies a 'substantial transformation' test: the country where the article last underwent a fundamental change in character or use is generally deemed the country of origin. For complex aerospace assemblies, this analysis can be highly fact-specific, and importers often seek binding CBP rulings to lock in the determination before entry.