Change the ITAR!
If you’re a space company, you must deal with export controls. The ITAR can be really cumbersome to deal with because it needs some serious updating. Great news! The State Department heard you. The official process by which you- the industry- can submit your requests for removing technology from the ITAR is on the way.
The State Department’s Directorate of Defense Trade Controls (“DDTC”), which implements the ITAR, is publishing an advanced notice of proposed rulemaking. Once published in the Federal Register, the request for public comments will call for input on technologies that should be considered for removal from the U.S. Munitions List. Additionally, comments should address new technologies not currently contemplated in the USML or otherwise. In other words, this is an opportunity for the private sector to
argue that certain technologies should no longer be subject to ITAR and to classify items that previously called for a lengthy commodity jurisdiction process.
This is an opportunity to advocate for critical equipment to be subject to less cumbersome and severe regulatory regimes. Any operator or manufacturer with ITAR-controlled
components or equipment should evaluate whether a case can be made for them to be subject to the less intensive Export Administrative Regulations. For companies with novel technologies that are difficult to classify, this is an opportunity to find a permanent home in the regulations and avoid ambiguity.
Does this apply to you?
+ I know this is important, but I don’t know how to participate.
+ I don’t have the time to sit down and draft effective comments.
+ I want to contribute my pieces of information to someone who can compile them into
something more significant and meaningful for the space industry.
We’d love for you to tell us things you’d like to see change on the ITAR so ACSP can take the initiative to compile comments to DDTC for you.
Write out your issues below. You can tell us in lay terms, and we’ll translate it into regulatory terms. Information that is helpful to us includes things like ITAR categories and export classifications. Also, give us a general idea of what the tech does, all the places it can be found in the commercial sector, and why you think it should be controlled differently. Also, tell us about situations in which technology was not clearly defined in the regulations and should have been.
DO NOT tell us proprietary or confidential information about your technology or that of anyone else.
DO NOT describe classified technology.
Email us your comments at info@acsp.space