Military Embedded Systems

Proposed revision to Category XI of USML commented on by IPC


February 01, 2013

Brandon Lewis

Technology Editor

Embedded Computing Design

Proposed revision to Category XI of USML commented on by IPC

BANNOCKBURN, IL. Global industry association IPC commented on the U.S. Department of State’s (DoS’s) proposed revision to Category XI (military electronics) of the U.S. Munitions List (USML) yesterday, urging the department to revise proposed language regarding controls on International Traffic in Arms Regulations (ITAR)-controlled PCBs for defense electronics. In the current draft of the proposed revision, the DoS states that controls for PCBs in “which the layout is ‘specially designed’ for defense articles,” verbiage that IPC believes could be articulated more clearly to address lasting confusion surrounding ITAR’s treatment of printed boards.

Concerned primarily with confusion that has resulted in inadvertent, unlicensed sourcing of PCBs for ITAR items from non-ITAR facilities, IPC suggested it be clarified that all printed boards are inherently specially designed, and that under paragraph d of the proposed rule, PCB designs and digital instructions constitute technical data. As an alternative, the organization issued the following replacement language in their comment: “to control under ITAR printed boards designed for ITAR-covered defense electronics.”

“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,” said Fern Abrams, IPC Director of Government Relations and Environmental Policy.

IPC does, however, support the level and scope of the draft rule controls that would be established for PCBs. John Mitchell, President and CEO of IPC, said, “IPC agrees with the State Department that strong and clear export controls on printed boards for defense electronics are necessary. 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.”

For the last year, IPC has conducted an educational campaign, “Follow the Law, Protect the Board,” to emphasize the importance of clear and unambiguous controls for printed boards to national security due to the information they contain about the workings of defense electronics. IPC’s comments are available at

More information on the proposed revision is available at


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