ITAR in PCBA Production: Insights You Might Be Missing

The U.S. Department of State (DoS) has a set of export control rules – the International Traffic in Arms Regulations (ITAR) – that ensure products on the United States Munitions List and Missile Technology Control Regime are controlled appropriately. Products within these categories include physical goods like firearms and tanks, as well as non-physical goods like technical data and classified articles.

Many individuals associate ITAR-regulated manufacturing solely with primary military equipment such as jets, tanks, and firearms. However, the actual classified list of items is far more extensive, encompassing gas turbines, related equipment, electronics, telecommunications, and even personal protective gear–essentially any sensitive technology that supports the US military or intelligence capabilities.

Only manufacturers that are ITAR-compliant can work on ITAR-classified projects, i.e., projects that produce assets that are essential to our national defense. And the way to prove ITAR compliance is to first become ITAR certified.

To become ITAR certified, manufacturers have to:

• Submit an application with the Directorate of Defense Trade Controls (DDTC) office within the DOS that describes how facilities participate in defense-related activities
• Pay a registration fee
• Renew the certification annually and demonstrate continued ITAR compliance

A crucial component of ITAR compliance is preventing unauthorized foreign nationals from accessing any intellectual property, which includes all information and data, as well as physical components involved in ITAR-classified projects. This necessitates a dual approach: implementing strong digital data management practices and maintaining physical security onsite. It’s essential that non-U.S. employees are unable to access spaces or information associated with ITAR-classified activities. This restriction also applies to U.S. employees who do not operate within ITAR- compliant facilities or zones.

Because the DoS allows manufacturers to decide exactly how they operate in line with ITAR standards, it is important for companies to provide ongoing training to employees involved in ITAR work and evaluate ITAR procedures regularly. Companies cannot afford to stray from their ITAR policies and procedures, since losing ITAR certification can result in major losses.

The U.S. State Department recently clarified misconceptions about Defense Export Controls, highlighting their vital role in safeguarding critical U.S. technologies, fortifying national security, and supporting global stability by minimizing diversion and proliferation risks. Here’s a breakdown of the clarifications they published.

• Under the ITAR, a number of exemptions allow speedy and secure defense trade, including an exemption for AUKUS that allows license-free transfers of both classified and unclassified defense articles.
• ITAR exists to safeguard U.S. technology, national security, and our competitive edge by preventing the transfer of items to unauthorized users or uses.
• It is possible for dual nationals to work on U.S.-origin defense technology under an ITAR exemption. In addition, DDTC offers additional licenses and authorizations for dual and third-country nationals if they prefer not to use the exemption.
• As part of the United States legal framework, transfers and assistance are regulated to prevent the diversion of critical technology and intelligence that could allow foreign adversaries to gain an advantage in military or intelligence operations.
• The ITAR no longer has jurisdiction over commodities or activities found to not provide a critical military or intelligence advantage.
• By implementing technology protection framework standards with key allies and partners, we combat the risks of transferring sensitive technology.

At MacroFab, we are dedicated to your success. Our US-based, ITAR-compliant facility is part of an extensive network of factories across North America, which includes locations in Mexico and Canada. This network ensures unlimited manufacturing capacity to support your growth needs for a variety of projects, both inside and outside the USA.

We are proud to be ITAR-registered, reflecting our commitment to meeting the highest standards of security and compliance. Our unique electronics manufacturing capabilities and platform enhance the quality and speed at which advanced electronics can be utilized in various applications.

Our engineers can assist you in designing flexible, powerful PCBAs, while our procurement teams can assist you in making informed decisions about parts purchases. To minimize risk and time-to-market, MacroFab’s platform aids in collaborating with both internal and external teams to manage inventory effectively and anticipate disruptions so you can finish projects faster with higher quality.

Security is our top priority. Only our US employees have access to ITAR-classified projects. While we collaborate with trusted partners in Mexico and Canada, partners and employees in those countries cannot access our ITAR-compliant facility, ITAR parts stored therein, or any data related to ITAR-classified projects. As part of our commitment to maintaining ITAR compliance, we provide specialized, ongoing training to all employees.

As a leader in electronics manufacturing, we felt a responsibility to offer our services to groups requiring the highest levels of compliance and security. The challenges of producing modern electronics at scale are increasing. Companies must deliver goods faster, and supply chains remain unpredictable. Through our extensive North American factory network and commitment to ITAR compliance, we are well-positioned to help you navigate these challenges with confidence.