Ensure Compliance with an ITAR Registered Fabricator
Registrant Code: M24495
Expiration Date: 04/30/2011
click for Registration Statement
Know your risks when it comes to ITAR
Confusion when it comes to ITAR can lead to enormous penalties, especially when it pertains to the outsourcing of sensitive materials to unauthorized countries.
What is ITAR?
The International Traffic in Arms Regulations is a set of regulations that govern the export and re-export of certain controlled commodities, services, and, most importantly, technologies.
United States Munitions List
In order to be controlled under ITAR as a defense article, a given component, subcomponent, part, assembly, subassembly, or integrated system must have been specifically designed, developed, configured, adapted, or modified for a military application controlled under the United States Munitions List.
If you are an EMS provider, ITAR is extremely important to your business as well as to your OEM customers. One of the biggest penalties can be a business shutdown while government investigates potential ITAR violations, which can often take months of inactivity while the government seizes computers, servers, and product.
For those PCB Assemblers or Contract Manufacturers who do no international business, there are still unexpected compliance risks such as foreign nationals working for you whom have access to work on technologically-sensitive projects. Furthermore, you may think that you are receiving US-made product because you are buying from a domestically located supplier. However, many US-based PCB suppliers also have an offshore brokerage side that sources product from Asian sources and resells them domestically.
Domestic companies outsourcing their IT project management for their networks must alert that provider that they have Export Control Information. This is an intellectual property issue. This also applies to PCB Designers seeking CAD/CAM software support which entails providing foreign support desk with access to their computer. That is an export and a licensable event.
No matter the administration, International Traffic in Arms Regulation rules will not fundamentally change. Export controls are here to stay. A common misconception is that this is in response to 9/11. But ITAR is not enforced solely due to the threat of terrorism. ITAR is looking ahead. It is imperative that we keep sensitive military and space technology away from potential enemies.
We realize that ITAR PCB manufacturing is more than government regulations. It is not some hassle of red tape. ITAR is about National Security and instilling the internal systems to make sure we comply 100% of the time.
ITAR Printed Circuit Boards
The Printed Circuit Board falls under Item 14—Category II of the United States Munitions List.
Item 14 - CATEGORY II
Analog-to-digital converters, usable in the system in Item 1, having either of the following characteristics:
Designed to meet military specifications for ruggedized equipment (see § 121.1, Category XI(d)); or,
Designed or modified for military use (see § 121.1, Category XI(d)); and being one of the following types:
Analog-to-digital converter ‘‘microcircuits,’’ which are ‘‘radiation hardened’’ or have all of the following characteristics:
Electrical input type analog-to-digital converter printed circuit boards or modules, with all of the following characteristics:
Having a resolution of 8 bits or more;
Rated for operation in the temperature range from below minus 45 degrees C to above plus 55 degrees C; and
Incorporated "microcircuits" listed in above