Status: FINAL — Rev. 2, October 6, 2026
Document ID: PGO-EXP-01
Effective Date: October 6, 2026
Compliance Contact: info@partgo.co | Support: support@partgo.co
PartGo LLC ("PartGo") operates a global manufacturing network connecting Customers in the United States with Manufacturing Partners primarily located in Türkiye. Due to the cross-border nature of this network, strict compliance with United States Export Control Laws is mandatory for all users of the PartGo platform.
Purpose & scope
This Export Control Policy ("Policy") governs the upload, transfer, and manufacturing of all 3D CAD models, 2D drawings, and technical specifications ("Technical Data") on the PartGo platform. This Policy applies to both Customers uploading Technical Data and Partners receiving Technical Data.
Prohibition of ITAR data
PartGo does NOT accept ITAR-controlled data.
The International Traffic in Arms Regulations (ITAR) (22 CFR Parts 120-130) strictly control the export of defense and military-related technologies. Because PartGo utilizes international manufacturing partners, Customers are strictly prohibited from uploading any Technical Data subject to ITAR to the PartGo platform.
Any Customer account found to be uploading ITAR-controlled data will be immediately suspended.
PartGo assumes no liability for ITAR violations caused by a Customer’s failure to properly classify their Technical Data before upload.
Customer obligations & EAR classification
Cross-border transmission or access to Technical Data from the United States to personnel or Manufacturing Partners in Türkiye may constitute an export under the U.S. Export Administration Regulations (EAR). A "deemed export" is a distinct EAR concept generally involving the release of controlled technology or source code to a foreign person in the United States. PartGo therefore requires Customers to provide accurate export-control information before controlled Technical Data is transferred outside the United States.
By uploading or submitting Technical Data, the Customer represents and warrants that:
1. The Technical Data is NOT subject to ITAR and is not classified information.
2. Unless PartGo expressly approves otherwise in writing before cross-border access, the Technical Data is EAR99 or otherwise eligible for export to Türkiye without a license under the EAR based on the applicable classification, end user, end use, destination, and authorization.
3. If the Technical Data has an ECCN other than EAR99, is subject to a license requirement, or involves a restricted end use/end user, the Customer must notify PartGo before upload or cross-border release and provide the classification and any required authorization. PartGo may decline or suspend the transaction until compliance is verified.
4. Customer shall provide truthful, complete, and sufficiently descriptive information concerning the intended end product, end use, industry/application, and other factual details reasonably requested by PartGo. Customer is not required to determine the U.S. HTS classification.
Partner obligations & embargoed countries
Manufacturing Partners (e.g., Turkish CNC shops) receiving Technical Data from PartGo must strictly comply with US Export Laws as well as the export control regime of the Republic of Türkiye (Ministry of Trade / Wassenaar Arrangement).
No Unauthorized Re-Export or Transshipment: The Partner shall not transfer, email, subcontract, re-export, or physically ship PartGo Technical Data or manufactured parts to any destination, end user, or end use prohibited or restricted under then-current U.S. or Turkish export-control or sanctions laws. The Partner shall not use Türkiye or any other jurisdiction as a transshipment point to evade applicable restrictions.
Restricted-Party Screening: The Partner shall not provide Technical Data or manufactured parts to a person or entity subject to applicable restrictions, including parties listed on relevant U.S. Treasury (OFAC) or U.S. Commerce Department restricted-party lists, without PartGo's prior written approval and any required government authorization. PartGo may update screening criteria as sanctions and export-control rules change.
Local Manufacturing Only: Unless explicitly authorized by PartGo in writing, all manufacturing must take place within the geographic borders of the Partner's registered country (e.g., Türkiye).
Affiliate Applicability: PartGo's related service providers, including PartGo İleri Teknoloji Hizmetleri A.Ş., which operates and maintains elements of the PartGo platform and may have operational access to Technical Data in that capacity, are subject to the same restrictions on access, retention, transshipment, and non-disclosure to Restricted Parties and embargoed destinations set out in this Section 4, and shall not provide Technical Data to any entity or individual identified in this Section.
PartGo’s right to screen & suspend
PartGo actively monitors its network for export control "red flags" (e.g., unusual shipping routes, lack of end-use information, suspicious payment structures). PartGo reserves the right to screen all transactions, request End-Use/End-User Certificates (EUC) from any Customer, and unilaterally refuse, halt, or suspend any transaction or account it reasonably believes may violate US or Turkish export control laws, without any liability to the Customer or Partner.
Indemnification
Both Customers and Partners agree to fully indemnify, defend, and hold harmless PartGo LLC, its executives, and affiliates from any fines, penalties, legal fees, or federal charges arising from their violation of this Export Control Policy or applicable US Export Laws.
By using the PartGo platform, both Customers and Partners acknowledge that they have read, understood, and agreed to strictly abide by this Export Control Policy.