Export Compliance – ITAR / DDTC / JCP
ICC complies with all applicable U.S. export control laws and regulations, including the International Traffic in Arms Regulations (ITAR), 22 CFR 120 et seq., the Arms Export Control Act (AECA), 22 USC 2751-2799, the Export Administration Act (EAA), 50 USC 2401-2420, the Export Administration Regulations (EAR), 15 CFR 730-774 and the regulations of the Office of Foreign Assets Control (OFAC), 31 CFR Parts 500-595. [These export laws cover defense articles, defense services and technical data and do not affect all military connectors and cable assemblies.]
ICC is registered with the US Department of State – Directorate of Defense Trade Controls (DDTC) for purposes of export licensing and renews this registration annually.
ICC is registered with the US/Canada Joint Certification Program (JCP) and maintains a current Military Critical Technical Data Agreement (DD Form 2345), under Certification Number 0020054.
FAR/DFARS Certifications and Representations
ICC is registered on the federal System for Award Management (SAM) database. ICC’s latest certifications and representations for applicable FAR and DFARS regulations and clauses can be accessed at www.sam.gov.
In addition, ICC’s sales and purchasing terms and conditions reference the specific FAR and DFARS with which we comply and flow down to our vendors.
RoHS / WEEE / REACH - Hazardous Substances Compliance
RoHS (Restriction of Hazardous Substances, Directive 2002/95/EC) restricts the use of specific hazardous materials found in electrical and electronic products. All applicable products in the EU market after July 1, 2006 must pass RoHS compliance.
The Waste Electrical and Electronic Equipment (WEEE) Directive is legislation that, in conjunction with RoHS, mandates targets for the collection, recovery and recycling of electronics and component materials.
Most of ICC-distributed products are not governed under the Restriction of use of certain Hazardous Substances (RoHS), Waste Electrical and Electronic Equipment (WEEE) and European Community Regulation on Chemicals (REACH), therefore are exempt from RoHS, WEEE and REACH directives.
Pending exemptions under RoHS and WEEE regarding specific applications of lead, mercury, cadmium, and hexavalent chromium are relevant to products which ICC distributes. Many customer specifications require specific plating that includes these controlled substances. Military products governed by MIL specifications (e.g. Federal Specification QQ-P-416 Plating, Cadmium and QQ-S-571F Federal Specification Solder, Electronic) remain unchanged and will be supplied in accordance with the applicable customer/military specification until the relevant standards organization agrees to the required changes regulated under RoHS and WEEE directives.
As a distributor, ICC cannot provide RoHS certification for any product. Certification is the responsibility of the component manufacturer. However, ICC is dedicated to helping our customers find information regarding RoHS and the products we supply. Please contact our Compliance Group directly if you have any questions regarding RoHS or WEEE certification.
Specialty Metals - DFARS 252.225-7009 (supersedes 252.225-7014)
Restriction on Acquisition of Certain Articles Containing Specialty Metals Flow-down Requirements and Processes
Most government and defense-related purchase orders placed by our customers are subject to the regulations and guidelines provided under the Defense Procurement and Acquisition Policy, DFARS 252.225-7009 Restriction on Acquisition of Certain Articles Containing Specialty Metals.
ICC includes this regulatory and compliance requirement on our electronic and printed purchase orders placed with our suppliers stating; “All products under this purchase order must comply with DFARS Clause 252.225-7009 - Restriction on Acquisition of Certain Articles Containing Specialty Metals.”
Our suppliers provide certificates of conformance with all shipments received, stating materials supplied are in accordance with ICC’s subject purchase order. If you require additional information regarding specific component level compliance with the regulations under DFARS 252.225-7009, please contact our Compliance Group.
Conflict Minerals - Dodd-Frank Wall Street Reform and Consumer Protection Act
ICC is not currently subject to the SEC final ruling and reporting requirements for conflict minerals for the following reasons:
- ICC is not a public company
- As a distributor, ICC does not have “influence over the manufacture of product” sold to our customers
- ICC supplies product built to military specifications, manufacturer’s proprietary specifications, or customer designs only
In an effort to respond to our customers who are requesting information, we have been in contact with those of our principal suppliers who are public companies and influence the manufacture of product and are, therefore, subject to the ruling.
Counterfeit Product Prevention and Awareness/GIDEP and ERAI Membership
ICC adheres to strict counterfeit product prevention and awareness processes, including counterfeit risk evaluations of suppliers which comply with AS5553 Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition. All purchasing, inspection, and receiving staff are trained thoroughly on these procedures.
ICC requires its suppliers, whether manufacturer or distributor, to furnish manufacturer certifications or certificates of conformance for all product lots. These certifications must include or must be traceable back to verification records. ICC maintains lot traceability throughout the product lifecycle, from receipt of goods through shipment. Per AS9100C, ICC suppliers must allow ICC and its customer’s access to the applicable quality records on demand.
ICC participates in GIDEP (Government Industry Data Exchange Program) and ERAI (Electronic Resellers Association International). Both resources provide up-to-the-minute reporting of counterfeit parts incidents.
GIDEP is a cooperative activity between government and industry participants seeking to reduce or eliminate expenditures of resources by sharing technical information essential during research, design, development, production and operational phases of the life cycle of systems, facilities and equipment.
The GIDEP database contains information about items that are potentially counterfeit. It is the responsibility of GIDEP members to perform extensive testing, analysis, and reporting on these items.
Our participation in both GIDEP and ERAI is just another testament to the quality and reliability of our systems and components -- translating into time and cost savings for both us and our customers.
ICC takes counterfeit part prevention and detection seriously. We are confident that our procedures and staff training are sufficient to insure that our customers will receive only genuine products from ICC, whether or not we are an authorized distributor for the items.