Export Control Reform

In the summer of 2014, SIA applauded the publication of new regulations that reformed the export controls for satellites and related items.  For more than 15 years, SIA promoted satellite export reform, actively advocating for legislation to enable change while participating extensively in the process to develop the final rules.

The U.S. Departments of State and Commerce each published rules transferring commercial communications satellites and some remote sensing satellites, along with tens of thousands of associated parts, components, and ground terminals from the more restrictive U.S. Munitions List to the Commerce Control List.  This action marked the end of a 15-year period during which all U.S. satellite exports were licensed as munitions, creating unnecessary constraints on U.S. satellite competitiveness internationally.  The Administration issued final rules less than 18 months after the U.S. Congress passed legislation permitting satellite export control reform, with bipartisan and bicameral support.

Today, SIA continues to lead the industry’s efforts to improve to the U.S. export licensing and policy framework for satellites, components, technical data, and ground equipment.  Today, much of satellite technology remains restricted under U.S. export control regulations, notably including items such as launch separation/integration technologies, electric propulsion, star trackers, rocket engines and motors, and apertures below one meter in size.  SIA encourages the continued review of commercially available technologies at the international level to ensure that ITAR-free components do not preclude the U.S. from being competitive in the international marketplace.

SIA has issued the attached responses in regard to the Directorate of Defense Trade Controls and Bureau of Industry and Security’s reviews of the U.S. Munitions List and Commerce Control List.

USML Categories IV and XV

Comment on Advanced Notice of Proposed Rulemaking Regarding Review of Commerce Control List for Items Transferred From United States Munitions List Categories IV and XV