President’s Message — Working to Clarify Defense Industry Understanding of ITAR Applicability to Printed Boards

by John Mitchell, IPC president and CEO

I just returned from Washington, D.C. where IPC held a workshop for defense OEMs on U.S. export control regulations for printed boards in defense-related electronics. As you may remember, this past July, IPC launched its Follow the Law, Protect the Board educational campaign with a series of meetings with U.S. State, Commerce and Defense department officials and key Congressional committees in Washington, D.C.

As a key element in the Follow the Law, Protect the Board initiative, the workshop was held to address continuing confusion in the industry on the applicability of International Traffic in Arms Regulations (ITAR) to printed boards.  Featuring two government speakers and an industry panel, the workshop provided an opportunity for OEMs to delve into the issues surrounding ITAR and printed boards.

The workshop began with a presentation by Peter Lichtenbaum, one of the nation’s leading ITAR lawyers, who explained the applicability of U.S. defense trade controls to printed boards. That presentation fueled an animated discussion that carried over into an industry panel on ITAR compliance best practices. The OEM representatives in attendance have implemented rigorous trade compliance regimes, and yet, there was general recognition among our private sector peers that greater clarity is necessary. Some of the workshop participants expressed a desire to work with IPC to achieve that goal in export control reform.

Attendees were also fortunate to hear from two federal officials. Mike Laychak, licensing director with the Defense Technology Security Administration at the U.S. Department of Defense provided a federal perspective on current and proposed rules governing military electronics, and later, U.S. Department of Commerce’s Assistant Secretary Kevin Wolf’s keynote described the administration’s approach to export control reform, focusing on Category XI. The open dialogue with key government officials made this event a valuable one for IPC and workshop attendees

It was our good fortune from a timing perspective that the U.S. State Department proposed revisions to Category XI (electronics) of the U.S. Munitions List (USML) two weeks prior to our event. The proposed changes included language consistent with that which IPC had been aggressively advocating, specifically, the explicit control of “printed boards.”

IPC’s advocacy is ongoing; we will be submitting formal comments to the State Department on ways the rule could be made clearer. We strongly encourage all of our members who are or may be providing electronics to defense-related programs to review the revisions and submit comments by the January 28 deadline. Please contact Fern Abrams, IPC director of government relations and environmental policy, for more information about submitting comments in support efforts.

If you would like to better understand how export controls might impact your organization, our final event for the Follow the Law, Protect the Board campaign will be a free BUZZ Session at IPC APEX EXPO 2013 in San Diego. Additionally, I invite you to attend the Government Relations Committee’s Open Forum to learn more about the Committee and discuss regulations and legislation affecting your company.

I am relatively new to the government relations area, but am encouraged by the IPC Board of Directors’ support for investing in the growth and improvement of this important member benefit. As always, I encourage you to send me your thoughts on what I cover in this article as well as your ideas on how we can make IPC an even greater benefit to our members (johnmitchell@ipc.org). Wishing you the very best in the New Year!

John Mitchell (left) and U.S. Department of Commerce Assistant Secretary, Kevin Wolf.

John Mitchell (left) and U.S. Department of Commerce Assistant Secretary, Kevin Wolf.

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