On January 9, 2025, DDTC’s new registration fee rates become effective. This is the first time in fifteen years DDTC has increased the registration fees charged to those who are required to register with DDTC pursuant to the Arms Export Control Act. Pursuant to the final rule amending parts 122 and 129 of the ITAR, published by the Department of State on December 10, 2024, the new registration fees are as detailed below.
| Registrant Tier | New Annual Registration Fee |
| Tier 1 Registrants (new registrants, registrants who have submitted license applications or other requests for authorization but have not received favorable determinations, brokers regardless of the number of favorable brokering determinations, and registrants who are wholly exempt from income taxation pursuant to 26 U.S.C. 501(c)(3)). | $3,000 (or $2,500 if the registrant can prove that $3,000 is one percent or more of their total revenue). |
| Tier 2 Registrants (registrants who have submitted license applications or other requests for authorization and received five or fewer favorable determinations). | $4,000 (or a pre-set alternate payment schedule if the registrant can prove their registration fees are greater than one percent of their total sales). |
| Tier 3 Registrants (registrants who have submitted license applications or other requests for authorization and received more than five favorable determinations). | $4,000 plus a $1,100 charge for each favorable determination beyond five (or three percent of the value of such authorizations, or $4,000, whichever is greater, if the registrant can prove that their total registration fee is greater than three percent of the total value of favorable determinations on license applications or other request for authorizations). |
Crowell & Moring, LLP continues to monitor export control developments and their potential impact on customers and businesses going forward.