IPC Files Comments on Second Proposal Regulations for Military Electronics under ITAR

In regulatory comments filed September 9, 2013, IPC commended the U.S. Department of State (DoS) Directorate of Defense Trade Controls (DDTC) on its decision to enumerate printed circuit boards (PCBs) in proposed revisions to Category XI (military electronics) of the U.S. Munitions List (USML). The DoS re-proposed the rule in order to solicit additional public comments on what is proving to be one of the most complex and difficult category revisions.

The draft rule’s treatment of printed boards is very similar to the draft rule released in November 2012. The newly proposed rule continues to support IPC’s position by enumerating printed boards on the ITAR. However, the proposed enumeration continues to rely on specially designed to determine the scope of ITAR’s coverage.

IPC continues to be concerned that DDTC’s proposed reliance on specially designed as the principal means of controlling PCBs will perpetuate confusion within the defense industry which, will lead to continued inadvertent and preventable ITAR violations.

In our comments, IPC urged DDTC to enhance the clarity of ITAR controls on PCBs in a manner that is consistent with the principle that the applicability of ITAR to PCBs should generally follow the defense articles for which they are designed.

For the past two years, IPC has been promoting a better understanding of ITAR’s applicability to PCBs in order to protect national security. Launched in July 2012, IPC’s Follow the Law, Protect the Board initiative sought to raise awareness and promote compliance with federal regulations on the export of printed boards designed for ITAR-controlled equipment.

See IPC’s full set of comments to DDTC.

More information about IPC’s advocacy efforts in the area of export controls are available at http://www.ipc.org/export-controls.

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