State Dept Seeks Input on Shifting Defense Gear Destinations
Published Date: 1/21/2026
Notice
Summary
The Department of State wants to keep collecting info from people or businesses who export or move defense hardware and licenses, especially when they change who uses it, how it’s used, or where it goes. They’re asking for public feedback for 60 days before renewing this process, which takes about an hour per form. If you’re involved in exporting defense stuff, this affects you and your paperwork time!
Analyzed Economic Effects
3 provisions identified: 1 benefits, 2 costs, 0 mixed.
Open General License (OGL) Pilot Program
The Directorate of Defense Trade Controls has launched a pilot Open General License (OGL) program under ITAR Sec. 120.22(b) that may authorize certain transfers of defense articles to predetermined parties. DDTC states OGLs eliminate the need for individual case-by-case review for certain lower-risk transactions and may provide flexibility for U.S. defense industry and allies to maintain, repair, and store defense articles.
Mandatory DS-6004 Submission Requirement
If you export or reexport defense hardware and need to change the end-user, end-use, or destination, you must submit Form DS-6004 (Reexport/Retransfer Application). The collection is mandatory, has OMB Control Number 1405-0173, and the Department estimates 1,695 respondents, 2,234 responses, an average of 1 hour per response, and a total estimated burden of 2,234 hours.
Five-Year Recordkeeping Requirement
If you reexport or retransfer defense articles (including under Open General Licenses), you must retain records for five years from the date of the transaction. Required records include a description of the defense article or service, quantity and value, end-user name and address and contact info, responsible natural person, stated end-use, transaction date, and method of transmission.
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Key Dates
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