LOST in Transit, LOST in Compliance:
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Why NVG ITAR Control Demands Operator Action By Adam Aldous, Night Flight Concepts Inc.
W hen it comes to night vision goggles
(NVGs), rotorcraft operators understand their critical role in mission success and safety. Far fewer realize the steep
regulatory cliff they’re standing on. NVGs are not just sensitive flight tools; they are classified as defense articles under the International Traffic in Arms Regulations (ITAR), specifically Category XII (c)(1) (i). That means ownership, use, transfer, and even shipment of these devices fall under strict federal control.
In today’s environment, the greatest compliance threat may not come from misuse, but instead from something as simple as a shipping label.
Why NVGs Are ITAR-Controlled and Why It Matters to You
ITAR Category XII (c)(1)(i) defines night vision systems as defense articles due to their sensitive military capabilities. This designation doesn’t just apply to manufacturers and government contractors; it also applies to civilian operators, law enforcement agencies, EMS providers, and even private flight schools that utilize NVGs.
If you operate NVGs, you are legally obligated to follow U.S. International Traffic in Arms Regulations (ITAR) rules that govern: • Who can access or use the equipment • Where and how it can be transferred • How it must be tracked, inspected, and stored
Violations of ITAR — whether intentional or through simple negligence — can lead to massive civil fines, criminal prosecution, and revocation of operating privileges.
The 180-Day Rule and the Growing Risk in Transit
Under FAA guidelines, NVGs must undergo an inspection for continued airworthiness every 180 days, typically at a certified FAA 145 Repair Station like Night Flight Concepts (NFC). This inspection ensures the optics, alignment, performance and safety of the equipment.
However, most operators don’t hand deliver their units, they ship them.
That’s where things get risky.
NVGs lost in transit become instant compliance liabilities. Because they’re ITAR-controlled, the operator is responsible for:
• Documenting the chain of custody
• Reporting the loss to the appropriate authorities
• Potentially triggering an investigation
NFC has seen a steady rise in shipping-related loss events over the past two years. In most cases, the operator assumed the equipment was insured and tracked properly — only to discover days later that the package disappeared, wasn’t signed for, or was mishandled by a third-party carrier.
A $10,000+ pair of NVGs gone. And now, you may be facing ITAR exposure.
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May/June 2025
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