Two US regimes you cannot ignore
ITAR — International Traffic in Arms Regulations
Administered by the US State Department (DDTC). Governs defence articles and services on the United States Munitions List (USML). Historically many satellites were USML-controlled.
EAR — Export Administration Regulations
Administered by the US Commerce Department (BIS). Governs dual-use goods on the Commerce Control List (CCL), including most commercial satellites and components after the 2014 satellite export reform.
Key concepts
- Deemed exports — disclosing controlled tech to a foreign national inside the US counts as an export.
- Re-transfers — moving items between foreign parties can require licenses even post-shipment.
- Jurisdiction disputes — if ITAR and EAR both seem to apply, file a Commodity Jurisdiction request with DDTC.
Pragmatic advice
- Build export classifications into component selection early. A single USML part can "taint" an entire assembly.
- Document the manufacturer's classification (ECCN for EAR, USML category for ITAR).
- For non-US founders working in the US, deemed-export compliance is existential.