Export-control notice
What you must determine before submitting technical data to Atherton Forge, what we do not accept, and how manufacturing location is handled for controlled projects.
Draft for review by counsel. This document has not yet been reviewed by an attorney. Effective date: to be set on publication.
1. Purpose
Atherton Forge coordinates manufacturing through a network of facilities located in the United States and Asia. Some technical data is subject to US export-control laws, including the Export Administration Regulations (EAR) administered by the Department of Commerce and the International Traffic in Arms Regulations (ITAR) administered by the Department of State. Transferring controlled technical data to a foreign facility, or to a foreign national in the United States, can require a license or be prohibited. This notice explains what we need from you to comply.
2. Your responsibility to classify
You are responsible for determining whether the technical data you submit — fabrication data, bills of materials, drawings, firmware, test procedures, and mechanical models — is subject to the EAR or the ITAR, and if so, its classification (for example, an Export Control Classification Number under the EAR, or a US Munitions List category under the ITAR). If you do not know, consult your export-compliance function or counsel before submitting files. We cannot classify your data for you.
3. What we do not accept
We do not accept ITAR-controlled technical data or defense articles under any circumstances through this website or the quote-request form. We do not accept EAR-controlled technical data classified other than EAR99 unless a written arrangement covering the specific project has been agreed in advance. Regulated manufacturing for aerospace, defense, automotive-safety systems, and medical life-support products is outside our scope.
4. Disclosure before you submit files
If your project involves technical data that is controlled, or that you believe may be controlled, do not upload files. State the situation in the notes field of the quote request, or contact legal@athertonforge.com, and we will tell you whether and how we can proceed before any files are transferred. Submitting files through the form constitutes your representation that they are not ITAR-controlled and are either not subject to the EAR or are classified EAR99, unless a written arrangement states otherwise.
5. Manufacturing location and transfers
The facility for each project is selected after file review and confirmed with you in writing, including its country, before any project files are transferred to it. You may state a manufacturing-location preference in the quote request. Where your compliance requirements limit manufacturing to the United States, say so, and the project will be planned accordingly or declined.
6. Sanctions and restricted parties
We comply with US sanctions and restricted-party regulations. We do not knowingly do business with sanctioned persons, entities, or destinations, and we may decline or suspend a project, or request additional information about end use and end users, in order to comply with applicable law.
7. Changes
Export-control requirements change. We may update this notice at any time, and the current version applies to submissions made after its effective date.
8. Contact
North Brookville LLC, a California limited liability company doing business as Atherton Forge
legal@athertonforge.com