ITAR Clarification on Satellite Thrusters
On October 4, 2018, the State Department issued minor revisions to the International Traffic in Arms Regulations (ITAR), including two changes related to space systems:
- In response to industry feedback, the State Department added a note clarifying that the rocket engine controls in Category IV(d) of the U.S. Munitions List (USML) do not apply to satellite and spacecraft thrusters. Such thrusters fall under USML Category XV(e)(12) or ECCN 9A515 of the Commerce Control List (CCL).
- The ITAR update also revised the definition of spacecraft-related defense services in USML Category XV(f), but without changing the actual scope of the controls.
DOC’s Bureau of Industry and Security (BIS) previously issued a revision to its regulations that provided further discussion on satellite thrusters and added them to ECCN 9A515.