In February, as a direct result of meetings IPC staff and members have had with the House Foreign Affairs Committee over the past eight months, Committee Chairman Ed Royce (R-CA) recently wrote to the U.S. Department of State (DoS) supporting our goal of clarifying the applicability of ITAR regulations to defense printed circuit boards (PCBs) by having them directly enumerated on the U.S. Munitions List (USML).
In the letter to Rose Gottemoeller, acting undersecretary for arms control and international security, Chairman Royce praised the DoS for recognizing the vital role of the printed circuit board industry in ensuring national security and highlighted industry concerns that the DoS’ proposed reliance on the term “specially designed” could be confusing.
In regulatory comments filed September 9, 2013, IPC commended DoS Directorate of Defense Trade Controls (DDTC) on its decision to enumerate PCBs in proposed revisions to Category XI (military electronics) of the U.S. Munitions List (USML). 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.