BANNOCKBURN, IL — The US State Department's proposed revisions to the Category XI (electronics) U.S. Munitions List (USML) explicitly list printed boards, a change from the current regulations.
The proposal, published Wednesday in the Federal Register, was quickly hailed as “an important step in the right direction,” by IPC president and CEO John Mitchell.
For more than a year, IPC has strongly urged the government to clarify International Traffic in Arms Regulations controls on printed boards through explicit enumeration on the USML. IPC has previously identified Category XI as the most appropriate place to regulate printed boards for USML-listed items.
“IPC appreciates that the State Department shares our view that ITAR’s regulation of printed boards should be clearer,” said Mitchell. “The electronics manufacturing industry, in turn, supports the State Department’s decision to control printed boards for ITAR covered defense articles in Category XI.”
While the draft rule represents real progress for IPC and its member companies, Mitchell adds that IPC will be submitting formal comments to the State Department on ways the rule could be made clearer. The draft rule identifies printed boards “specially designed” for defense articles, but in fact, all printed boards are “specially designed.” The inclusion of the term “specially designed” in reference to printed boards mistakenly implies the existence of commercial off-the-shelf (COTS) printed boards.
“We are concerned that this language could perpetuate the erroneous belief among some in the defense industry of the existence of non-specially designed PCBs for ITAR items that would not be controlled by ITAR,” says Fern Abrams, IPC director of government relations and environmental policy.
Before the Federal Register deadline of Jan. 28, IPC will submit comments to the State Department on the proposed revisions.