Dec 13, 2012 IPC today hosted an educational workshop for the country’s leading defense contractors on International Traffic in Arms Regulations’ (ITAR) applicability to printed boards. The workshop featuring senior government officials and leading export control practitioners was organized as part of IPC’s Follow the Law, Protect the Board educational campaign to raise awareness and promote compliance with federal regulations on the export of printed boards designed for ITAR-controlled equipment.
“Domestic printed board manufacturers have sounded an alarm that defense industry confusion over ITAR’s treatment of printed boards is undermining national security,” said IPC President and CEO John Mitchell. “IPC is grateful for the opportunity to partner with federal officials in workshops like this to clarify current and proposed export control regulations.”
Today’s workshop and the broader educational campaign of which it is a part were organized by IPC to address concerns that some defense contractors source printed boards for ITAR items from non-ITAR facilities. Although not listed explicitly on the United States Munitions List (USML), the export of printed boards and their designs are regulated by ITAR as “specifically designed parts and components.”
As Brent Grazman, vice president of quality, Viasystems explained, "It is important for our customers to pay attention to export compliance issues in their supply chain in addition to those related to their end items. This starts with clear communication about purchases, such as PCBs destined for use in ITAR covered products." Grazman suggests that defense contractors "ensure that their PCB supplier has developed a rigorous compliance system to protect from supply disruption and possible enforcement activity."
In July 2012, IPC launched Follow the Law, Protect the Board in Washington, D.C. by meeting with members of Congress, senior staff at the Department of State and other executive branch officials. IPC also released a white paper titled, Applicability of U.S. Defense Trade Controls to Printed Boards. Authored by Covington and Burling’s Peter Lichtenbaum, one of the nation’s foremost ITAR experts, the white paper explains in plain language and with concrete examples companies’ ITAR obligations with respect to printed boards.
In November, the State Department published a proposed rule for USML Category XI revisions. That rule explicitly controls printed boards “specially designed” for ITAR covered items. IPC, which has urged for explicit enumeration of printed boards on the USML, commended the State Department for taking this positive step in clarifying ITAR’s treatment of printed boards.
For more information on IPC’s educational initiative, Follow the Law, Protect the Board, visit www.ipc.org/export-controls or contact Fern Abrams, IPC director of government relations and environmental policy, at FernAbrams@ipc.org. To register for the upcoming export controls session at IPC APEX EXPO 2013, visit www.IPCAPEXEXPO.org/register.
IPC (www.IPC.org) is a global industry association based in Bannockburn, Ill., dedicated to the competitive excellence and financial success of its 3,300 member companies which represent all facets of the electronics industry, including design, printed board manufacturing, electronics assembly and test. As a member-driven organization and leading source for industry standards, training, market research and public policy advocacy, IPC supports programs to meet the needs of an estimated $2.02 trillion global electronics industry. IPC maintains additional offices in Taos, N.M.; Arlington, Va.; Stockholm, Sweden; Moscow, Russia; Bangalore, India; Bangkok, Thailand; and Shanghai, Shenzhen and Beijing, China.
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