Hi,
Well, lol...lots actually but I learned not to attempt ITAR, DDTC, etc talk on forums because of all the "professionals" that want to attempt to argue, lolol.
Here is the short and sweet for clarity:
1. Suppressors have ALWAYS been allowed to be exported by USA based companies (Not USA Gov itself). They just had to be exported to .gov entities following same process as below and NOT to civilian end users.
2. The new policy is putting suppressors into the same export category and process that firearms used to be in. The exporter (Not the USA Gov itself) must get an import permit, EUC, signed DSP83, signed PO, etc from the buyer then complete the DSP5 (Permanent Exportation of unclassified items) and submit everything to the DDTC. DDTC will review each case just as they use to do with firearms and still do with everything else on Sec 121 of USML. Then DDTC will either approve or deny. The exporter then lodges the approved DSP5 and all other documents into the AES and delivers the package to the freight forwarder listed on the DSP5.
3. To any suppressor mfg here reading this, lol....Be sure to put a designator in your serial number scheme to differentiate between USA and International suppressors. It will help make it easier to calculate your FET.
Sincerely,
Theis