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Department of State Draft Rulemakings Explicitly List Printed Boards in Category XI — Military Electronics IPC Views as a Preliminary but Significant Achievement

Nov 30, 2012

The explicit listing of printed boards in the U.S. State Department’s proposed revisions to the Category XI (electronics) U.S. Munitions List (USML) published yesterday in the Federal Register is, “an important step in the right direction,” said IPC President & CEO John Mitchell. For more than a year, IPC has strongly urged the government to clarify International Traffic in Arms Regulations (ITAR) 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,” stated 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 January 28, 2013, IPC will submit comments to the State Department on the proposed revisions. After which, IPC will post a link to its comments at www.ipc.org/export-controls as well as in an upcoming issue of IPC Outlook.

Information on IPC’s advocacy efforts in the area of export controls is available at www.ipc.org/export-controls. This includes details on an IPC educational initiative, Follow the Law, Protect the Board, which launched in 2012 to clarify the importance of controlling printed boards designed for ITAR controlled items.

IPC will also host a free BUZZ session “Export Controls: Understanding ITAR and its Reform,” at IPC APEX EXPO 2013 on February 20. To register, visit www.IPCAPEXEXPO.org/register.


IPC (www.IPC.org) is a global industry association based in Bannockburn, Ill., dedicated to the competitive excellence and financial success of its 3,300 member companies which represent all facets of the electronics industry, including design, printed board manufacturing, electronics assembly and test. As a member-driven organization and leading source for industry standards, training, market research and public policy advocacy, IPC supports programs to meet the needs of an estimated $2.02 trillion global electronics industry. IPC maintains additional offices in Taos, N.M.; Arlington, Va.; Stockholm, Sweden; Moscow, Russia; Bangalore, India; and Shanghai, Shenzhen and Beijing, China.

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