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IPC Comments on Proposed Revisions to USML Category XI on Military Electronics
BANNOCKBURN, IL —  
In regulatory comments filed yesterday, IPC commended the U.S. State Department for enumerating printed boards in proposed revisions to Category XI (military electronics) of the U.S. Munitions List (USML). IPC also urged the State department to modify the proposed language to more clearly express the controls on PCBs for ITAR-controlled defense electronics.

IPC has, for the past year, conducted an educational campaign, Follow the Law, Protect the Board, to highlight the importance to national security of clear, unambiguous controls for PCBs because of the important information they contain about the workings of defense electronics for which they are uniquely designed.

“IPC agrees with the State Department that strong and clear export controls on printed boards for defense electronics are necessary,” said IPC President and CEO John Mitchell. “IPC is grateful for the opportunity, afforded by this regulatory process, to affirm our support for the enumeration of printed boards and to offer the industry’s recommendations on further clarifying the treatment of printed boards on the USML.”

The State Department’s draft rule for Category XI controls printed boards for “which the layout is ‘specially designed’ for defense articles.” While IPC supports the level and scope of controls that the draft rule would establish for printed boards, it believes that the intent could be more clearly articulated to address longstanding confusion about ITAR’s treatment of printed boards. This confusion has inadvertently resulted in the unlicensed sourcing of printed boards for ITAR items from non-ITAR facilities.

“We are most concerned that the use of specially designed could perpetuate the erroneous belief that there are non-specially designed printed boards, leading companies to disregard ITAR controls on PCBs,” says Fern Abrams, IPC director of government relations and environmental policy.

IPC has offered alternative language that more clearly captures the State Department’s end goal: to control under ITAR printed boards designed for ITAR-covered defense electronics. IPC has also urged the State Department to make clear in its final rule that all printed boards are, by their very nature, specially designed and that designs and digital instructions for printed boards constitute technical data under paragraph (d) of the proposed rule.

IPC’s comments and more information about its advocacy efforts in the area of export controls are available at www.ipc.org/export-controls.

IPC will host a free BUZZ session “Export Controls: Understanding ITAR and its Reform,” at IPC APEX EXPO 2013 on February 20. In addition, IPC’s Government Relations Committee will host an open forum on Tuesday, February 19 to discuss, and get input on, its on-going efforts to support the prosperity of the global electronics manufacturing industry.
 

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