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.

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