Military Embedded Systems

Proposed revision to USML military electronics, ITAR issued by State Department


December 07, 2012

Brandon Lewis

Technology Editor

Embedded Computing Design

WASHINGTON. The Directorate of Defense Trade Controls (DDTC) of the U.S. Department of State has published a proposition for revision to Category XI of the U.S. Munitions List (USML), which covers military electronics, in an attempt to create what they call a “bright line” between the Commerce Control List (CCL) and USML. Included in the proposal is a definition of “equipment,” as well as a more exact description of electronics that warrant control on the USML. Following a 60-day comment period that commenced on November 28, 2012, the Department of State may elect to implement none, all, or some of the proposed revision.

The proposed Category XI revision clarifies military electronics that are covered under the International Traffic in Arms Regulations (ITAR) versus those regulated by Export Administration Regulations (EAR). This would serve to remove military computers from the USML and transfer control to the Department of Commerce’s Bureau of Industry and Security (BIS) under the Export Control Classification Number (ECCN) 3A611.

Responsible for implementation of ITAR, the DDTC controls export of items on the USML, including defense services, defense-related technical data, and all military articles. Regardless of whether they are critical to the preservation of U.S. military superiority, current guidelines hold parts or components or components that have been designed or modified specifically for a defense article subject to ITAR regulation. The proposed revision to the USML category contains a proviso for a positive list of specific categories of attachments, accessories, components, and parts that require continuous USML control.

Also specified by the proposed rule are defense articles in the general categories of Command, Control, and Communications (C3) identification systems and equipment, electronic combat equipment, equipment and systems, radar systems and equipment, and underwater hardware. Several additional provisions to electronic sensor systems for anti-submarine warfare, mine warfare and concealed weapons, testing devices for radio controlled Improvised Explosive Device (IED) Electronic Warfare (EW) systems, and unattended ground sensors on the USML are also added. Equipment for analysis and processing of military equipment under Category XI of the USML is also expressly covered.

The proposition also explicitly defines “equipment” as a “combination of parts, components, accessories, firmware, or software that operate together to perform a specialized function of an end-item or system.”


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