It is ATW’s expectation that all suppliers shall comply with certain business and ethical standards, as well as the laws of their countries and all other applicable laws, rules and regulations.

Additionally, suppliers accepting purchase orders from ATW Companies facilities agree to adhere to the following guidelines.

Unless otherwise noted on the Purchase Order, suppliers are also required to adhere to the following regulatory requirements:


International Traffic in Arms Regulations (ITAR) is a set of United States government regulations that control the export and import of defense-related articles and services on the United States Munitions List. These regulations implement the provisions of the Arms Export Control Act, and are described in Title 22 (Foreign Relations), Chapter I (Department of State), Subchapter M of the Code of Federal Regulations. The Department of State interprets and enforces ITAR. Its goal is to advance national strategic objectives and U.S. foreign policy via the trade controls.


RoHS, also known as Lead-Free, stands for Restriction of Hazardous Substances. RoHS, also known as Directive 2002/95/EC, originated in the European Union and restricts the use of six hazardous materials found in a variety of product. All Suppliers shall know and understand the contents of its products, including the products of its Suppliers. Suppliers shall provide a complete listing of the product’s, or services, physical contents to ATW to demonstrate compliance if required. If necessary, ATW may require documentation from the Supplier certifying their product to be RoHS compliant.

ATW suppliers are required to adhere to the following RoHS guidelines with regards to materials content:

  • Lead (Pb): < 1000 ppm
  • Mercury (Hg): < 100 ppm
  • Cadmium (Cd): < 100 ppm
  • Hexavalent Chromium: (Cr VI) < 1000 ppm
  • Polybrominated Biphenyls (PBB): < 1000 ppm
  • Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm


The European Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) entered into force in June 2007. Suppliers shall comply with all applicable REACH requirements that affect the products they supply to ATW. ATW expects Suppliers will have a dialogue with their own supply chain and with ATW regarding all applicable aspects of REACH

3TG (Conflict Minerals) Section 1502 of the Dodd-Frank Act of 2010

ATW is contractually required to report the unintentional use of certain minerals from the Democratic Republic of Congo (DRC) and countries that share its border (“the DRC region”). The minerals specifically identified are tin, tungsten, tantalum, and gold (known as “3TG minerals”). The 3TG minerals are present in the manufacture of a wide variety of commercial products. ATW suppliers are required to disclose to ATW if the product or services provided to ATW contain these minerals.

DPAS Rated Orders

ATW occasionally accepts orders or contracts that fall under the provisions of the Defense Priorities and Allocation System (DPAS).

The purpose of the DPAS is to:

Assure timely delivery of materials and services from private industry to meet National Defense needs,

Provide an operating system to support rapid industry response to Government Procurement needs in times of need. ATW will not designate individual POs as DPAS rated. ATW suppliers should be aware of, and prepared to, meet the requirements of DPAS for all POs.