Export Controls reform , impact on aerospace


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How French and Foreign Aerospace companies can benefit from removing ITAR designation on key technologies

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Export Controls reform , impact on aerospace

  1. 1. US Export Reform: Impact on Aerospace Presented by Jahna Hartwig August 13, 2013
  2. 2. Background > President’s National Export Initiative (NEI) – goal of doubling U.S. exports over five years > Federal agencies working to streamline U.S. export controls in support of NEI – building higher walls around the most sensitive items – allowing exports of less critical items under less restrictive conditions > Proposals to move many military end-items and their systems, subsystems, parts, components, and technologies from the U.S. Munitions List (USML) to the Commerce Control List (CCL) 2
  3. 3. Export Reform Effort > Most items moved to CCL will be > Controlled for national security reasons > Require a license for export to all destinations except Canada > Eligible for broad license exceptions > Eligible for de minimis treatment when incorporated into a foreign article 3 > Some end-items, as well as many parts and components, will be less strictly controlled for export and re-export. > Manufacturers, exporters and brokers of moved items would no longer be required to register with US State Department
  4. 4. Status of Reform Efforts April 16, 2013 - Finalized Categories VIII and XIX • Finalized USML Category VIII (Aircraft) • Moved some ITAR-controlled aircraft to CCL Category 9 • Added USML Category XIX (Gas Turbine Engines) Changes effective October 15, 2013 4
  5. 5. UAV Controls after Reform ITAR-Controlled UAVs • Unarmed military UAVs • Armed UAVs • Target drones Other ITAR-Controlled Aircraft include: • Military intelligence, surveillance, and reconnaissance aircraft • Electronic warfare, airborne warning and control aircraft • Optionally Piloted Vehicles (OPV) 5
  6. 6. UAV Controls after Reform ITAR-Controlled UAV Items Moving to CCL (ECCN 9A610) • Apparatus and devices ‘‘specially designed’’ for the handling, control, activation and non-ship-based launching of UAVs or drones controlled by either USML paragraph VIII(a) or ECCN 9A610.a, and capable of a range equal to or greater than 300 km. • Radar altimeters designed or modified for use in UAVs or drones controlled by either USML paragraph VIII(a) or ECCN 9A610.a., and capable of delivering at least 500 kilograms payload to a range of at least 300 km. • Hydraulic, mechanical, electro-optical, or electromechanical flight control systems (including fly-by-wire systems) and attitude control equipment designed or modified for UAVs or drones controlled by either USML paragraph VIII(a) or ECCN 9A610.a., and capable of delivering at least 500 kilograms payload to a range of at least 300 km. 6
  7. 7. UAV Controls after Reform EAR-Controlled UAVs (ECCN 9A012) UAVs having any of the following: • Autonomous flight control and navigation capability; or • Capability of controlled flight out of direct visual range involving human operator (e.g., televisual remote control) Associated systems, equipment and components, as follows: • Equipment specially designed for remotely controlling UAVs listed above; • Navigation, attitude, guidance or control specially designed to provide autonomous flight control or navigation capability described above; • Equipment or components specially designed to convert manned aircraft to a UAV described above; • Certain engines specially designed/modified to propel UAVs at altitudes above 50,000 feet (15,240 meters). 7
  8. 8. Cyber Security ITAR – U.S. Munitions List • Software specifically designed for a military application may be subject to the International Traffic in Arms Regulations. Specifically designed and military application are undefined. Export Control Reform • The U.S. Government is currently reviewing the relevant portions of the U.S. Munitions List that may impact how certain security software is controlled for export purposes. U.S. Senate Proposal for Controls • U.S. Senate proposal in National Defense Authorization Act for 2014 to require the Executive Branch to establish a policy to control the proliferation of cyber weapons. This may involve the use of export controls or economic sanctions. 8
  9. 9. Questions? 9