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APPLICABILITY OF U.S. DEFENSE TRADE
CONTROLS TO PRINTED BOARDS
DECEMBER 12, 2012
Peter Lichtenbaum
(202) 662-5557
[email protected]
Overview
• Background on printed boards
• Current ITAR controls
• Export control reform
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Printed Boards: What are they? What
do they do?
• Conductive printed wires attached to rigid,
insulating sheet of fiberglass-reinforced
polymer (aka “board” or “substrate”).
• PCBs connect active components (microchips
and transistors) and passive components
(sensors and fuses) into an electronic
assembly that controls a system.
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Specially Designed Nature of
Printed Boards
“An important element of [printed boards] is that
they are usually product-unique”.
SOURCE: LINKAGES: MANUFACTURING TRENDS IN ELECTRONIC
INTERCONNECTION TECHNOLOGY, NATIONAL ACADEMY OF SCIENCES,
2005
• Each printed board is specifically and
uniquely designed for the products into which
it is incorporated
• Printed boards are not “COTS” products
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Printed Board Designs
• Electronic data file, often supplemented with
drawings: provides roadmap for the electronic
operation of the item for which it is designed
• Materials used in circuit board construction
including special properties functionality
• Design and placement of parts and
components
• Designed flow of information through the
circuit board, between components and to the
system in which it is installed
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Printed Boards are
Vital to National Defense
“The effectiveness of defense systems
depends on the underlying
PrCB [printed board] technology.”
SOURCE: LINKAGES: MANUFACTURING TRENDS IN ELECTRONIC INTERCONNECTION
TECHNOLOGY
NATIONAL ACADEMY OF SCIENCES
2005
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Why the PCB is Important to National
Security
– The PCB is the basic building block for all military
electronics.
– It incorporates all the Intellectual Property that is
contained in the design.
– The information contained in the PCB data could be
used to reverse-engineer our systems.
– The PCB has become a functional part of the system
on complex hardware like radar systems.
– The designs and material selections on systems like
Space Based Radar determine the performance of
the system.
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Military Significance of Printed
Boards
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Electronic warfare systems
Flight communication radios
Integrated avionics
Smart munitions fuse
IED jammers and detectors
Unmanned air and ground vehicles (UAVs
and UGVs)
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Printed Boards Contain Vital Intellectual
Property in DoD Electronics
AMRAAM Missile
PBs
PBs
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Printed Boards Contain Vital Intellectual
Property in DoD Electronics
TRIDENT II U.S. Navy’s Fleet Ballistic Missile
PBs
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Example: Printed Boards for Flight
Controls
• Design of the printed boards for flight controls
can reveal the data buses used in the controls
• Data buses are the communications channels
between the flight computer and the aircraft
control surfaces
• Access to data bus types can provide U.S.
adversaries with information about potential
weaknesses of the aircraft, including how
sensitive the aircraft is to electronic disruption
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Relevant ITAR Provisions
• Category XI(c): “Components…specifically
designed or modified for use with [XI(a) or (b)
equipment], except for such items as are in
normal commercial use”
• Category VIII(h) components “specifically
designed or modified” for items in VIII(a)-(d);
other similar components categories in USML
• Technical data that is “directly related” to
these components: XI(d), VIII(i), etc.
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Basic ITAR Approach
• Export jurisdiction over the printed board, or
the board design, depends on the product it is
designed for: ITAR or EAR
• Boards designed for defense articles
generally presumed ITAR, until DDTC rules
otherwise
– Cat. XI(c) “normal commercial use”
• Boards designed for EAR products are EAR,
even if the EAR product will be installed on a
defense platform
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Commodity Jurisdiction (CJ) Rulings
• Limited information available publicly on
DDTC site: post-2010, summary descriptions
• Artwork “unpopulated circuit board” – XII(e)
• Sensor Concepts circuit boards for reflectivity
analysis system – XI(c)
• Data Device Corp. PMC circuit card
implementing data bus protocols (1553,
ARINC429, RS-422) – EAR99
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Proposed Cat. XI Rule (Nov. 28)
• “Printed circuit boards or patterned multichip
modules for which the layout is ‘specially
designed’ for defense articles in this
subchapter.”
• “Technical data directly related to [such
items]”
• An important confirmation
– But can the approach be further improved to
provide greater clarity?
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Comments and Questions?
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