Training & Education

FAQ: Is ITAR and EAR Information also CUI on DoD Contracts?

Training & Education

FAQ: Is ITAR and EAR Information also CUI on DoD Contracts?

by Josh Manuel on Dec 19 2025
Prepared by DTCGlobal.us for CUISupply.com Summary: Yes. When ITAR or EAR-controlled technical data or technology is used, created, or required to perform a U.S. Department of Defense (DoD) contract or subcontract at all tiers, it qualifies as Controlled Unclassified Information (CUI) and must be protected accordingly. The most direct answer comes from: See DoD Procurement Toolbox, Cybersecurity FAQ #22.and Question #28. Look below to learn how CUI Supply products can help you meet these requirements. CUI Supply products support compliance by helping organizations clearly identify and protect export-controlled CUI during the performance of the contract in controlled environments or CUI zones such as: Engineering offices Manufacturing floors Quality and test areas Visitor and customer access zones Through signage, labeling, zoning, and visual-control mechanisms, CUI Supply helps prevent unauthorized disclosure of ITAR- and EAR-restricted information, aligning day-to-day operations with DoD CUI and export-control requirements. What This Means for Manufacturing Companies Many manufacturing organizations mistakenly treat export control (ITAR/EAR) and CUI/CMMC as separate compliance efforts. Under DoD contracts, they are closely connected. ITAR and EAR determine who is allowed access to technical data and technology. CUI requirements determine how that information must be identified, marked, and protected. When export-controlled information supports DoD contract performance, both sets of requirements apply at the same time. When ITAR / EAR Information Becomes CUI Export-controlled information qualifies as CUI when it is: Provided by the DoD, or Generated by your company while performing a DoD contract, and Required to be protected by law, regulation, or government-wide policy. In these cases, the information is typically categorized as: CUI // Export Control (EXPT) Often overlapping with Controlled Technical Information (CTI) Common Examples in Manufacturing This includes, but is not limited to: Engineering drawings and CAD files Technical data packages Manufacturing and process instructions Specifications, tolerances, and test data Quality and inspection documentation If these materials are ITAR- or EAR-restricted and tied to a DoD contract, they must be treated as CUI. What You Are Expected to Do When DFARS 252.204-7012 is included in your contract, your organization must: Identify export-controlled information involved in contract performance Mark it as CUI in accordance with DoD guidance Protect it using appropriate physical, visual, procedural, and system safeguards Control access, including preventing unauthorized foreign-person exposure This applies whether the information was: Received from the government, or Created by your company during contract performance CUI Zones and Manufacturing Environments In manufacturing settings, CUI protection is not limited to IT systems. Export-controlled CUI often exists in physical spaces, such as: Engineering offices Manufacturing floors Quality and test areas Areas where visitors or customers may be present These areas commonly require CUI Zones, which use signage, labeling, access controls, and visual barriers to prevent unauthorized disclosure. Why This Matters Failing to treat ITAR- or EAR-controlled information as CUI can result in: Compliance gaps under DFARS 252.204-7012 CMMC assessment or DoD audit failures Yes – the DoD does audit subcontractors Export-control violations Increased contractual and regulatory risk Treating export control and CUI as a single, coordinated compliance obligation helps prevent these issues. IMPORTANT: You must also fully meet all ITAR/EAR export control program (minimum) requirements under DDTC and BIS guidance. See disclaimer below.  Authoritative References (Basic Set) 32 CFR Part 2002 – Controlled Unclassified Information DoDI 5200.48 – DoD CUI Policy DoDI 5230.24 – Controlled Technical Information DFARS 252.204-7012 – Safeguarding CUI NARA CUI Registry – Export Control (EXPT) ITAR (22 CFR Parts 120–130) EAR (15 CFR Parts 730–774)  LEARN MORE: For detailed regulatory analysis and citation mapping, see the “Advanced” FAQ version of this guidance How CUI Supply Products Help Meet CUI, ITAR, and EAR Safeguarding Requirements  CUI Supply products support the identification, awareness, and safeguarding of Controlled Unclassified Information (CUI), including export-controlled technical data subject to ITAR and EAR. By providing clear visual indicators, standardized markings, and reusable protection systems, CUI Supply helps organizations communicate access restrictions, warn unauthorized individuals, and reduce the risk of inadvertent disclosure in real-world environments. CUI Supply products: Support implementation and enforcement of CUI requirements Provide observable evidence of safeguarding practices for customer visits,  assessments, and audits. Do not replace policies, training, legal determinations, or system security controls CUI Supply products provide physical, visual, and procedural enforcement mechanisms that support an organization’s obligation to identify, mark, restrict access to, and prevent unauthorized disclosure of Controlled Unclassified Information (CUI), including export-controlled technical data subject to ITAR and EAR. These products do not replace policies or information system controls. Instead, they enable practical, observable compliance in real-world engineering, manufacturing, and visitor-access environments. CUI Identification, Awareness, and Safeguarding (How CUI Supply Products Support These Objectives)  Requirement Objectives Organizations handling Controlled Unclassified Information (CUI), including export-controlled technical data subject to ITAR and EAR, must ensure that: Personnel can readily recognize CUI and understand when special handling, access, and safeguarding requirements apply. CUI is properly identified, marked, and communicated so that authorized individuals understand applicable distribution restrictions and handling requirements. Individuals who are not authorized to access CUI are clearly warned of restricted content and associated regulatory requirements, helping prevent inadvertent or unauthorized disclosure. These objectives apply across offices, engineering spaces, manufacturing floors, test areas, and visitor-accessible environments, where CUI may be present even when not immediately visible. How CUI Supply Helps Meet These Objectives CUI Supply products provide practical, visual, and repeatable mechanisms that help organizations operationalize CUI identification and safeguarding requirements in day-to-day environments. Clear CUI Identification & Awareness CUI category signage and labels (e.g., CTI, EXPT / ITAR / EAR) reinforce correct recognition of export-controlled CUI. Standardized terminology and iconography align personnel understanding with DoD and federal CUI categories. Persistent visual cues reduce reliance on memory or training alone. Outcome: Personnel can immediately recognize when CUI is present and understand that special handling applies. Area-Level Marking & Environmental Awareness Area-level markings (e.g., CUI Zones, Controlled Viewing Areas) indicate that CUI may be present even when individual documents, screens, or workpieces are not visible. Boundary and transition indicators help distinguish public, controlled, and restricted spaces. Color-coded and standardized visual cues reduce ambiguity for employees, visitors, and escorts.  Outcome: Unauthorized individuals are warned before entering or observing restricted environments, reducing inadvertent exposure.  Communication of Distribution & Access Restrictions Export-control warning signage communicates ITAR/EAR access limitations, including foreign-person restrictions. “Authorized Access Only” and “Escort Required” indicators reinforce distribution controls at the point of use. Consistent labeling language supports uniform understanding across shifts, facilities, and sites. Outcome: Distribution restrictions are clearly communicated to both authorized and unauthorized individuals, supporting compliance and enforcement. Rapid Document Identification & Protection Document covers, sleeves, and reusable marking systems allow organizations to quickly identify, mark, and protect CUI. Reusable and durable solutions support high-tempo environments where documents are frequently created, moved, or reviewed. Temporary protection mechanisms help prevent unauthorized disclosure during reviews, meetings, audits, or production activities. Outcome: CUI is protected quickly and efficiently without disrupting operational workflows. Disclaimer This material is provided for general informational and educational purposes only and does not constitute legal advice, export control advice, cybersecurity advice, or a definitive compliance determination. The identification and handling of Controlled Unclassified Information (CUI), including export-controlled technical data subject to the International Traffic in Arms Regulations (ITAR) or the Export Administration Regulations (EAR), is fact-specific and contract-dependent. Obligations may arise from statutes, regulations, DoD policy, contract clauses, program direction, or written Government authorization. Organizations are responsible for reviewing their specific contracts, regulatory obligations, and applicable Government guidance, and for consulting with qualified legal counsel, export compliance professionals, or contracting officers as appropriate. Use of CUI Supply products or materials does not by itself ensure compliance with CUI, export control, DFARS, or CMMC requirements. You can do this. Roll up your sleeves and get to work. Our mission is to help YOU #ProtectCUI

Training & Education

FAQ: Is ITAR and EAR also CUI? 

by Josh Manuel on Dec 19 2025
A common misconception is that ITAR or EAR compliance is separate from CUI or CMMC. Export-controlled information that is used, generated, or required for performance of a DoD contract qualifies as CUI. This FAQ answer offers authoritative, cited guidance from key regulations (32 CFR Part 2002, DoD Instructions 5200.48 and 5230.24, NARA CUI Registry) to ensure proper identification, marking, and facility-based protections of this highly regulated technical information. For DoD contractors, export-controlled technical data and technology under ITAR and EAR qualify as Controlled Unclassified Information (CUI) in the Export Control (EXPT) category when provided by or generated during DoD contract performance, requiring proper CUI marking (e.g., DoD marking guidance) on all documents, files, and media to prevent unauthorized disclosure.  This same information demands robust safeguarding through designated CUI Zones—controlled physical and digital areas (such as engineering offices, manufacturing floors, quality/test labs, and visitor access points) equipped with signage, labeling, access controls, and visual/perceptual barriers to protect against inadvertent exposure to unauthorized persons, including foreign nationals restricted under ITAR/EAR. These marking and zoning requirements are integral to DFARS 252.204-7012 and CMMC compliance, combining ITAR/EAR access restrictions with CUI safeguarding obligations; failing to treat them as unified can lead to compliance gaps and contract risks.  On U.S. Department of Defense (DoD) contracts, technical data and technology controlled under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR) qualify as Controlled Unclassified Information (CUI) when they are used, generated, or handled in support of contract performance. This is because DoD policy explicitly requires that export-controlled information be protected as CUI to prevent unauthorized disclosure, including disclosure to unauthorized foreign persons. When implementing DFARS 252.204-7012 and preparing for CMMC certification you must implement DoD policy
CMMC Mythbusters- CMMC 2.0/ DFARS Training & Education Series

Training & Education

CMMC Mythbusters- CMMC 2.0/ DFARS Training & Education Series

by Hunter Edens on Oct 30 2025
CMMC Mythbusters is BACK December 2025! The popular CMMC 2.0/ DFARS training and education series CMMC Mythbusters returns December 15th- 19th, 2025! Once a six-part series, we have now condensed down to three parts, jam-packed with the latest updates and info you need to know to be compliant.  Join us live for the highly anticipated return of CMMC Mythbusters, led by the Chairman of the CMMC Industry Standards Council (CISC) and Chief Transformation Officer of DTC Global, Regan Edens. Sign up for each part via the links below:  Part 1: "What Exactly Is CUI (Controlled Unclassified Information)?" Part 2: "Commercial-Off-the-Shelf (COTS) vs CUI?" Part 3: "Identifying & Properly Marking CUI" This complimentary series is brought to by CUI Supply, DTC Global, and the University of Texas- Arlington. 

Training & Education

Are You Ready? | CMMC Phase I is HERE!

by Hunter Edens on Oct 10 2025
CMMC Phase I is officially HERE! Are you ready to go? Read more about the Final Rule below: Prepare with CUI Supplies HERE: https://cuisupply.com/
CMMC Phase 1 Officially Begins NOVEMBER 10TH, 2025!

Training & Education

CMMC Phase 1 Officially Begins NOVEMBER 10TH, 2025!

by Hunter Edens on Sep 09 2025
❗❗ATTENTION ❗ ❗CMMC Phase I officially begins NOVEMBER 10TH, 2025! If you haven't started preparing already, the time is NOW! We want to help you get ready. Get 10% off your order total, automatically applied at checkout, at CUISupply.com.DO NOT WAIT! Get ready NOW. To read more about the Final Rule, click HERE:
Important clarifications provided by the DoD were recently released on the CMMC Phase I Affirmation timeline and the impact on contracts after the effective date. The deadline is September 2025... Are you ready?

Training & Education

CMMC Phase I Affirmation is HERE!

by Hunter Edens on May 30 2025
Important clarifications provided by the DoD were recently released on the CMMC Phase I timeline and the impact on contracts after the effective date. The deadline is September 2025... Are you ready? 

Training & Education

WATCH HERE: Insights from the The DoD's New CUI Marking Aid

by Hunter Edens on May 01 2025
Join Regan Edens as he dives into the details of the DoD’s new CUI Marking Training Aid. You need to know what’s in it and how it’s going to affect your organization. 

Training & Education

The New DoD CUI Marking Training Aid, December 2024

by Regan Edens on Mar 03 2025
The DoD has quietly released a new CUI Marking Training Aid.... we are working on the date to dive into the details in a CMMC War Room podcast. Date and Time TBD. You can take a look at it yourself by downloading it here.