DEFENCE · NATO AQAP · STANAG · DUAL-USE 2021/821 · ITAR · ASD S1000D

NATO STANAG, AQAP and dual-use export controls resolved in 3 seconds.

IgeraIndustria gives defence primes, Tier 1/2 suppliers and export control managers instant access to NATO interoperability standards, AQAP-2110 quality requirements, EU Dual-Use Regulation 2021/821, ITAR category mapping and ASD S1000D technical documentation — citing the exact STANAG, clause or regulation article.

NATO STANAG library pre-indexed AQAP-2110 + EU Dual-Use Regulation included <3s response

Defence compliance: layered NATO, EU and US export control obligations on every contract

A single defence supply contract can simultaneously invoke NATO STANAG performance requirements, AQAP-2110 quality obligations, EU Dual-Use export licences, ITAR deemed-export controls on US-origin technology, and ASD S1000D technical documentation. No single team member has all of these mapped. IgeraIndustria does.

1,300+

Active NATO STANAGs covering interoperability requirements from ammunition to communications to logistics support. Navigating which STANAGs apply to a specific programme SOW requires specialist knowledge most Tier 2 suppliers lack.

AQAP-2110

NATO quality assurance requirement Edition 4 (2016) — adds a mandatory contract Quality Plan, GQAR government oversight, FAI per AS9102 and concession control not required by ISO 9001. Failure to comply voids the NATO certificate of conformance.

21 USML

ITAR US Munitions List categories. A deemed export — sharing controlled technical data with a non-US person even within the EU — requires a licence. Violations carry criminal penalties up to USD 1M per violation and debarment from US government contracts.

Reg. 2021/821

EU Dual-Use Regulation recast in force from September 2021. New Article 4 catch-all controls, cyber-surveillance items added, and reinforced end-user statement obligations. Exporters failing to conduct end-use checks face criminal liability under member state law.

Defence programmes are where compliance failures are most costly. A missed STANAG requirement triggers contract non-conformance. An unreported ITAR deemed export can result in criminal prosecution. IgeraIndustria puts the complete regulatory reference at your team’s fingertips — so compliance is built into the programme from day one, not discovered at source approval review.

Instant answers on NATO standards, export controls and defence documentation

IgeraIndustria locates the applicable STANAG, AQAP clause, ITAR category or Dual-Use Annex I entry and responds with the exact requirement, obligation and documented information needed.

NATO STANAG applicability by programme and product

Identify which STANAGs apply to a specific equipment category, system interface or logistics support requirement. Covers STANAG 4107 (mutual acceptance of government quality assurance), STANAG 4159 (configuration management), STANAG 3910 (aircraft systems), STANAG 2115 (military load classification) and 1,300+ others.

AQAP-2110 contract Quality Plan requirements

Structure a Quality Plan compliant with AQAP-2110 Edition 4: scope, applicable clauses, GQAR surveillance points, First Article Inspection (FAI) per AS9102, key characteristics identification, concession and deviation control procedure, and subcontractor quality flow-down requirements.

EU Dual-Use Regulation 2021/821 — Annex I classification

Determine whether your product, software or technology falls within Annex I of Regulation 2021/821, the applicable control category (1-9), the specific entry and technical parameter that triggers control, and which EU General Export Authorisation (EU001-EU008) may cover the export without an individual licence.

ITAR USML category determination and deemed export obligations

Map your product or technical data to the applicable US Munitions List (USML) category (I-XXI), identify whether a commodity jurisdiction (CJ) determination request to DDTC is required, and understand deemed export obligations when sharing data with non-US engineers within your EU facility.

UK Export Control Act 2002 — post-Brexit dual-use controls

The UK Export Control Order 2008 (as amended) controls dual-use items under the UK Strategic Export Control List (SIEL, OIEL, OGL). Post-Brexit, UK exporters cannot use EU General Export Authorisations. IgeraIndustria identifies which UK Open General Export Licence (OGEL) applies, or whether a Standard Individual Export Licence (SIEL) is required from ECJU.

ASD S1000D Issue 5 — data module structure and BREX compliance

Structure technical documentation compliant with ASD S1000D Issue 5: data module code (DMC) construction, applicable data module types (descriptive, procedural, fault isolation, IPD), Business Rules Exchange (BREX) constraints, applicability filtering for multi-variant systems, and Common Source Database (CSDB) management requirements.

NATO interoperability: STANAG compliance from proposal to delivery

NATO multi-nation programmes require equipment and systems that interoperate across 32 member nations. STANAGs define the minimum requirements. IgeraIndustria retrieves the applicable STANAGs at every programme phase.

Proposal phase — STANAG compliance matrix

During bid preparation, IgeraIndustria identifies all STANAGs referenced in the Request for Proposal (RFP) or Statement of Work (SOW), maps them to your product or system, and flags compliance gaps that require design action or a waiver request before contract award.

Design phase — STANAG technical requirements

Retrieves the specific technical parameters defined in applicable STANAGs — interface dimensions, performance thresholds, environmental test requirements, electromagnetic compatibility limits — so design engineers can incorporate them without manual standard searching.

Production phase — AQAP Government Quality Assurance

AQAP-2110 requires the supplier to define Government Quality Assurance (GQA) surveillance points in the Quality Plan — those stages where the GQAR must witness or verify before proceeding. IgeraIndustria identifies which production activities typically require GQAR presence based on AQAP-2110 requirements.

First Article Inspection — AS9102 requirements under AQAP

Most AQAP-2110 contracts require FAI per AS9102 (Rev B or C). IgeraIndustria retrieves the AS9102 FAI package requirements: Design Characteristic Accountability, Material Accountability, Dimensional Results, Functional Test Results, and the FAI report format accepted by the GQAR.

Configuration management — STANAG 4159

NATO configuration management per STANAG 4159 requires a Configuration Management Plan (CMP) covering baseline identification, change control, configuration status accounting and configuration audit. IgeraIndustria retrieves the STANAG 4159 requirements applicable to your contract configuration item (CI) level.

Delivery — NATO Certificate of Conformance and release documentation

NATO equipment deliveries require a NATO Certificate of Conformance (CoC) signed by the GQAR. IgeraIndustria identifies the release documentation required: NATO CoC, test reports, FAI records, traceability documentation, and the packing and marking requirements per applicable STANAGs.

EU Dual-Use, ITAR and UK Export Control Act: key differences for Tier 1/2 suppliers

European defence Tier 1/2 suppliers frequently encounter all three export control regimes simultaneously. Understanding where each applies and where they overlap is critical to avoiding unintentional violations.

EU Dual-Use Regulation 2021/821 — scope and reach

Applies to all exports from the EU of items listed in Annex I. Recast in 2021 to add human rights considerations (cyber-surveillance items), reinforce catch-all controls under Article 4, and require exporters to implement an Internal Compliance Programme (ICP). The ICP is not mandatory but provides a “due diligence defence” in enforcement proceedings. EU General Export Authorisations (EU001-EU008) cover exports to low-risk destinations of certain categories without an individual licence — but the exporter must register, keep records for 5 years, and notify the competent authority in some cases.

ITAR — extraterritorial reach and deemed export risk

ITAR has extraterritorial application: it applies to US-origin items and technical data anywhere in the world. A deemed export occurs when controlled technical data is disclosed to a non-US person — including your own engineers at your EU facility if they are not US persons. This means that when a US prime sub-licenses technology under a Technology Assistance Agreement (TAA) or Manufacturing Licence Agreement (MLA), the European manufacturer must manage deemed export compliance internally. ITAR violations carry criminal penalties under 22 USC 2778 of up to USD 1M per violation and 20 years imprisonment.

UK Export Control Act 2002 — post-Brexit divergence

Since Brexit, the UK has its own Strategic Export Controls that no longer track the EU Dual-Use Regulation. The UK Strategic Export Control List (SECL) is based on the Wassenaar Arrangement but diverges in some areas. UK exporters can no longer use EU General Export Authorisations — they must use UK Open General Export Licences (OGELs) or apply for a Standard Individual Export Licence (SIEL) or Open Individual Export Licence (OIEL) from ECJU (part of DBT). For UK-to-EU transfers of dual-use items, normal EU import procedures apply — no EU export licence is required for intra-EU receipt from the UK.

EAR — Commerce Control List for items not on the USML

The US Export Administration Regulations (EAR) control items on the Commerce Control List (CCL) — primarily commercial items with military applications not controlled under ITAR. The CCL uses Export Control Classification Numbers (ECCNs) — e.g. 3A001 (electronic components), 7A994 (inertial navigation systems). If an item is not on the USML or CCL, it is classified EAR99 — no licence required for most destinations. However, EAR99 items can still require a licence under EAR Part 744 end-user and end-use controls. IgeraIndustria determines whether your item is ITAR, EAR (with ECCN) or EAR99 based on product characteristics.

How IgeraIndustria works for defence and export control teams

Five steps from loading your programme documentation to receiving answers with exact STANAG reference, AQAP clause, USML category or Dual-Use Annex I entry.

01

Index your programme and compliance documentation

Upload your programme SOW, contract Quality Plan, approved supplier list, export control commodity classifications, TAA/MLA licences and technical data packages. IgeraIndustria processes them alongside the NATO STANAG library, AQAP-2110, EU Dual-Use Regulation 2021/821 and ITAR/EAR reference data in under 24 hours.

02

Connect the assistant to your programme team

Embed in the programme management portal, SharePoint, Teams or as a restricted-access widget for your export control and contracts team. Single sign-on integration available. One line of code.

03

The team asks in plain English

“Which STANAGs apply to our Eurofighter ECS component supply?”, “Does our composite wing spar fall under ITAR Category VIII or EAR?”, “What GQA surveillance points does AQAP-2110 require for our Quality Plan?”

04

IgeraIndustria searches 2 layers of programme knowledge

First in your internal programme documentation (SOW, QP, export licences, supplier quals), then in the indexed NATO STANAG library, AQAP-2110 Edition 4, EU Dual-Use Regulation 2021/821 Annex I, ITAR USML categories and ASD S1000D Issue 5.

05

Answer with STANAG, clause, category and compliance action

The response cites the applicable STANAG number and title, AQAP-2110 clause, USML category or Dual-Use Annex I entry, the specific requirement triggered, and the documented information or licence action required to achieve compliance.

IgeraIndustria in action — ITAR vs EAR determination for aerospace component

Export control classification query resolved in under 3 seconds, returning the applicable USML category, ECCN or EAR99 status with deemed export obligations.

IgeraIndustria — Defence & Export Control Widget

Export Control Manager

We manufacture titanium airframe structural brackets supplied to a Eurofighter prime under a UK MoD contract. Do these fall under ITAR Category VIII or EAR? We have US engineers with access to the drawings.

IgeraIndustria

ITAR vs EAR — Eurofighter Airframe Structural Brackets

  • Classification: ITAR USML Category VIII(f) — military aircraft parts, components and accessories specifically designed or modified for military aircraft
  • Eurofighter basis: Typhoon is a military aircraft designed to Category VIII — structural airframe brackets specifically designed for it are USML-controlled even if the item itself has no inherent military function
  • Deemed export risk: US engineers accessing technical drawings (CAD, stress analysis, tolerances) = deemed export requiring TAA or MLA with DDTC. No CJ determination needed — Category VIII(f) applies
  • Action required: (1) Restrict US engineers access to drawings until TAA is in place; (2) Contact US prime or UK MoD ITAR focal point; (3) If no US-origin technology in design, request commodity jurisdiction (CJ) from DDTC to confirm UK/EU origin removes ITAR control

⚠️ Consult your legal counsel and DDTC before disclosing drawings to US engineers pending TAA confirmation.

✓ ITAR USML Cat. VIII(f) · 22 CFR Part 121 · Confidence: 97.3%

450

employees, Tier 1 aerospace/defence

0

ITAR deemed export violations since deployment

-65%

export control classification time

We supply structural components to three NATO programmes simultaneously, each with different STANAG references in the SOW and overlapping ITAR/EAR obligations. Before IgeraIndustria, our export control manager spent days manually cross-referencing USML categories, EU Dual-Use Annex I entries and UK OGEL conditions for each new product introduction. Now we get the classification in seconds — with the STANAG reference, AQAP-2110 clause and the specific deemed export obligation flagged before we share any drawing.

Export Control & Compliance Director

Tier 1 aerospace/defence supplier — 450 employees — UK/Spain

*Representative testimonial based on results from real customers

Frequently asked questions — Defence & Military Compliance

NATO STANAG vs MIL-SPEC: which applies to your defence product?

STANAGs (Standardization Agreements) are NATO-wide interoperability standards agreed by member nations — they define minimum performance and interface requirements so equipment from different nations operates together. MIL-SPECs (US Military Specifications) are unilateral US DoD procurement documents specifying design, materials and manufacturing requirements for items procured by the US military. If your customer is a NATO prime contractor delivering to a multi-nation programme (e.g. Eurofighter, NH90, OCCAR-managed programmes), the applicable standard is the STANAG referenced in the contract Statement of Work (SOW). If you are supplying directly to the US DoD or a US prime under a Foreign Military Sale (FMS), MIL-SPECs apply. Many European Tier 1 suppliers must comply with both simultaneously — IgeraIndustria maps the overlap and identifies where a single process can satisfy both requirements without duplicate documentation.

AQAP-2110 vs ISO 9001 for defence contracts: what are the additional requirements?

AQAP-2110 (Edition 4, 2016) is the NATO quality assurance requirement for design, development and production. It builds on ISO 9001:2015 and adds mandatory requirements that commercial ISO 9001 does not cover: (1) a Quality Plan (QP) specific to the contract, agreed with the Government Quality Assurance Representative (GQAR); (2) configuration management aligned with STANAG 4159; (3) first article inspection (FAI) requirements aligned with AS9102; (4) nonconformance reporting to the GQAR — some NCs require government approval before use-as-is disposition; (5) concession and deviation control with government notification obligations; (6) preservation, packaging and marking to military specifications. For components supplied under AQAP-2110, the supplier quality management system must be assessed by a NATO accredited certification body — not just any ISO 9001 registrar. IgeraIndustria retrieves the specific AQAP-2110 clause requirements and maps them to your existing ISO 9001 system.

EU Dual-Use Regulation 2021/821 Article 2: what qualifies as dual-use?

EU Regulation 2021/821 (recast) defines dual-use items in Article 2(1) as items — including software and technology — that can be used for both civil and military purposes. The Regulation applies to items listed in Annex I (Common Military List equivalent for dual-use), which mirrors the Wassenaar Arrangement control lists covering: (1) Advanced Materials (Category 1), (2) Materials Processing (Category 2), (3) Electronics (Category 3), (4) Computers (Category 4), (5) Telecommunications (Category 5), (6) Sensors and Lasers (Category 6), (7) Navigation and Avionics (Category 7), (8) Marine (Category 8), (9) Aerospace and Propulsion (Category 9). A key Article 4 catch-all clause allows member states to require authorisation for non-listed items if the exporter has reason to believe they could contribute to WMD programmes. Exporters must conduct an end-use check for all dual-use items regardless of whether an export licence is required. IgeraIndustria retrieves the specific Annex I entry, control reason and applicable EU General Export Authorisations (EU001-EU008) for your product.

ITAR Categories I-XXI: how to determine which applies to your product?

The US International Traffic in Arms Regulations (ITAR) control items on the US Munitions List (USML), which is divided into 21 Categories (I to XXI). Key categories for European industrial suppliers: Category I (Firearms); Category IV (Launch vehicles, guided missiles — critical for space and missile defence primes); Category VI (Vessels of war — naval programmes); Category VIII (Aircraft — any military aircraft, UAVs, aircraft engines including dual-use gas turbine components); Category XI (Military electronics — radar, EW systems); Category XII (Fire control, range finder, optical systems); Category XV (Spacecraft and related articles — critical for satellite programmes); Category XIX (Gas turbine engines). The determination of whether your item falls under ITAR (USML) or EAR (Commerce Control List, CCL) requires a commodity jurisdiction (CJ) determination request to the US State Department DDTC if there is ambiguity. ITAR controls apply to the item, its technical data and defence services — including sharing technical data with non-US persons (deemed export). IgeraIndustria identifies the applicable USML category based on product description and flags deemed export obligations for your engineering team.

ASD S1000D Issue 5: technical documentation requirements for military programmes

ASD S1000D is the international specification for the procurement and production of technical publications for military and civil aviation equipment. Issue 5.0 (2019) is the current baseline for most NATO programmes. S1000D structures technical information as Common Source Data Modules (CSDMs) stored in a Common Source Database (CSDB) — not as traditional document files. Key data module types: Descriptive (describe system/component), Procedural (maintenance tasks), Fault isolation (troubleshooting), Illustrated Parts Data (IPD), Wiring data. The Business Rules Exchange (BREX) module defines the programme-specific rules that constrain which S1000D elements are permitted — suppliers must comply with the customer BREX before authoring. Applicability filtering allows one CSDB to serve multiple aircraft/system variants. For UK MoD programmes, JSP 886 Volume 4 defines the S1000D contractual baseline alongside DEF STAN 00-600. IgeraIndustria retrieves the specific data module schema requirements, BREX constraints and applicability coding rules for your programme.

NATO security classification: from COSMIC TOP SECRET to UNCLASSIFIED — handling obligations

NATO uses a four-level classification system: COSMIC TOP SECRET (CTS) — highest level, unauthorised disclosure would cause exceptionally grave damage to NATO; NATO SECRET (NS) — serious damage; NATO CONFIDENTIAL (NC) — damage; NATO RESTRICTED (NR) — disadvantageous. UNCLASSIFIED NATO (NU) information has no classification but is still controlled. Industrial suppliers handling NATO classified information must hold a Facility Security Clearance (FSC) at the appropriate level, granted by the national security authority (in Spain: CNI; UK: UKSV). Personnel accessing classified information must hold a Personnel Security Clearance (PSC). Physical and IT security requirements are defined in STANAG 4422 (physical security) and STANAG 4785 (Cyber/IT security for NATO CIS). The NATO Industrial Security Directive (C-M(2002)49) governs the industrial security programme. Key obligations: need-to-know access control, transmission with classified coversheet, destruction certificates for no-longer-needed copies, incident reporting within 24 hours to the national security authority and NATO. IgeraIndustria maps the specific handling, storage and transmission requirements by classification level for your programme security instructions (PSI).

IgeraIndustria Defence & Military Compliance plans

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