News & Publications

Changes to Export Regulations Involving Satellites

On May 13, 2014, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) published regulations expected to significantly change export controls on civil and commercial satellites and their related articles. 

These new regulatory changes will impact the civil and commercial satellite industry as the export of certain items becomes less restrictive. The changes are expected to provide considerable national and economic benefits. BIS has issued an interim final rule that “adds controls to the Export Administration Regulations (EAR) for spacecraft and related items that the President has determined no longer warrant control under United States Munitions List (USML) Category XV—spacecraft and related items.” 

The rule plans to move many commercial satellites and related items off of the USML and back to the Commerce Control List (CCL). New Export Control Classification Numbers (ECCN) 9A515 (spacecraft, ground stations and specifically designed parts, components, accessories and attachments); 9B515 (related test, inspection and production equipment, and specially designed parts and components); 9D515 (related software), and 9E515 (related technology) will control the items being moved in addition to existing ECCNs. Spacecraft that have commercial end-use capabilities above a specified threshold will continue to be controlled on the USML.

Changes to the rules are set to be implemented in two phases, with the first occurring on June 27 when controls for radiation-hardened microelectronic circuits are removed from the USML, and ITAR controls on software and technical data associated with microelectronic circuits are taken from USML XV(f). The second phase of the final rule goes into effect 180 days after the May 13 publication (approximately November 13), when the remainder of the USML will be revised and the additional changes in the rule become effective.

During the 180-day period, BIS seeks feedback on the changes to the EAR and USML related to commercial and civil spacecraft. BIS will study if additional revisions should be made to place control of military or intelligence spacecraft on the USML, while moving nearly all civil and commercial spacecraft to the CCL. 

Do these new regulations impact your business? If you would like to know how you are affected or if you have any other trade compliance related questions please contact Allyn at (239) 489-9900 or you can email us at


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