U.S. Export Controls
U.S. export controls include the laws and regulations managing the sale or transfer of sensitive goods and technology, services, and expertise to non-U.S. citizens. First implemented 60 years ago, U.S. export controls were intended to restrict the ability of foreign nations to access to sensitive technologies and commodities. Since its inception, the export controls system has been modified to address technological advancements and emerging national security concerns. These modifications, however, have resulted in an overly broad and complex set of regulations that neither adequately protect national security, nor facilitate export opportunities.
Currently, printed boards are not listed explicitly in International Traffic in Arms Regulations (ITAR), but they are covered in ITAR’s catch-all listing pertaining to “specifically designed parts and components.” Printed boards, in fact, are always custom designed — a process that requires access to technical information about the workings of the end product. IPC companies that manufacture boards for ITAR items make considerable investments to ensure that highly sensitive technical data remains secure. Our national security is undermined when this information is shared internationally without the approval of the U.S. government.
Because printed boards are not listed explicitly in ITAR, a careful analysis of the complex ITAR rules is required in order to properly understand the control of printed boards and their designs. As a result, the applicable controls may be overlooked, resulting in inadvertent violations of the law that undermine U.S. national security. IPC analysis indicates that roughly one-third of printed boards manufactured for military use are made outside the United States. Anecdotal evidence indicates that this may include the unlicensed sourcing of ITAR-controlled printed boards from non-ITAR facilities.
In response to the industry confusion over ITAR’s treatment of printed boards, IPC has pursued a two-pronged strategy — the first of which seeks clarification of current ITAR rules for printed boards and the second seeks specific inclusion of printed boards and their designs on a revised U.S. Munitions List (USML). Only by achieving both goals will federal regulators make clear to the exporting and manufacturing communities that printed boards for ITAR items share the same controls as the end-use items into which they are incorporated.
Learn more about U.S. Export Controls and IPC’s advocacy:
To share your thoughts on proposed changes to U.S. export control reform or to obtain more information about IPC’s policy goals, please contact Fern Abrams, IPC director of government relations and environmental policy, at FernAbrams@ipc.org or +1 847-597-2952.