Export control space really boils down to the rules that shape how spacecraft, launch vehicles, and related tech move across borders. The government uses these controls to protect national security, mostly through licensing, and decides which countries get access to specific space technologies.
These regulations touch every commercial space activity, big or small. If you want to ship a satellite part overseas, you’re probably dealing with export controls.
Space-related export controls cover a huge range of stuff, and it all falls under two main sets of rules. The Export Administration Regulations (EAR) handle dual-use items—basically things that could be used for both civilian and military purposes. The International Traffic in Arms Regulations (ITAR) focus on defense-related space tech.
The EAR lists items on the Commerce Control List, like spacecraft parts, remote sensing satellites, and space logistics systems. Some recent updates have made it easier to export less sensitive spacecraft parts to close allies such as Australia, Canada, and the UK.
ITAR, on the other hand, deals with military-grade space tech under the U.S. Munitions List Categories IV and XV. That covers stuff like advanced propulsion, military satellites, and special space-based defense gear. The latest regulations have carved out some new exemptions for civil space activities, space tourism, and research partnerships.
Key controlled items include:
You really need to know the lingo to get through export control compliance. An export means you’re sending controlled items from the U.S. to another country, while a reexport is when an item gets shipped from one foreign country to another.
License exemptions let you skip the usual permits in some cases. The new Commercial Space Activities exemption helps with space tourism and research. There’s also the Official Space Agency Exemption, which supports government space program collaborations.
Export Control Classification Numbers (ECCNs) are used to pinpoint exactly what’s on the Commerce Control List. ECCN 9A515, for example, covers a bunch of spacecraft types, while 9E515 is for related tech. Companies need to figure out the right classification for their products—no shortcuts here.
Deemed exports happen when foreign nationals inside the U.S. get access to controlled tech. That’s a big deal for international space companies with mixed teams. Even space tourism companies have to keep this in mind when training foreign participants.
The fundamental research exemption lets universities and research groups share certain space info without licenses. That’s a win for academic collaboration in space sciences.
Export controls have a serious impact on global commercial space and international partnerships. The October 2024 updates try to boost U.S. space industry competitiveness but still keep security in mind. They’ll cut out about 90 license applications each year for exports to trusted allies.
Foreign policy shapes a lot of these control decisions. The U.S. uses these rules to keep sensitive tech away from adversaries, but they also make it easier for allies to get certain items. There’s always a balancing act between business interests and security.
International Space Station operations get special treatment under the new rules. License Exception GOV lets some exports go to Russia for ISS missions, which keeps collaboration going even when politics get tricky. It’s a rare example of space cooperation rising above diplomatic tensions.
If you’re a commercial space company working internationally, you need to know the rules for your destination country. Exports to China, Russia, and Venezuela face much tougher controls than shipments to NATO countries. Launching from international waters? You still have to follow the controlling country’s regulations.
Space tourism companies run into their own set of headaches when serving international customers. New exemptions for tourism activities require FAA flight path approval and U.S. person ownership of the spacecraft. That can really shape how companies plan and operate.
The U.S. government sets the rules for exporting space tech using two main systems, each handling different categories of space items and technologies. These regulations define how commercial space companies can share their tech with global partners and customers.
The International Traffic in Arms Regulations focus on the most sensitive space tech—the stuff that could give military or intelligence advantages. The State Department’s Directorate of Defense Trade Controls runs the show here.
ITAR covers items on the U.S. Munitions List. Think advanced spacecraft systems, some satellite tech, and specialized space gear. Companies have to get State Department licenses before exporting any of these to foreign entities.
These rules want lots of technical details. Foreign nationals working on ITAR-controlled projects need special approvals. Even sharing a technical drawing might trigger a licensing requirement.
Some recent updates propose moving certain space items from ITAR to the Commerce Department. For example, spacecraft with refueling capabilities or those with autonomous collision avoidance systems. Those don’t give the U.S. the same military edge as before.
The Export Administration Regulations handle commercial space tech with lower security risks. The Bureau of Industry and Security (BIS) inside the Commerce Department manages these.
BIS dropped license requirements for some spacecraft components shipped to over 40 allied nations. They also stopped requiring licenses for remote sensing and space logistics items sent to Australia, Canada, and the UK.
These changes reflect just how fast the commercial space sector is growing. Tech that used to be sensitive is now everywhere. So, the regulations focus on the most critical stuff and let routine business run more smoothly.
License exceptions make it easier to export to NASA programs and close allies. Companies can use these exceptions for certain space activities without having to apply for a license every single time.
The Bureau of Industry and Security at Commerce handles commercial space export controls. BIS teams up with NASA and NOAA to check the health of the civil space industry and suggest regulatory tweaks.
The State Department’s Directorate of Defense Trade Controls takes care of the most sensitive military and intelligence-related space tech. DDTC works with BIS when moving items between the two systems.
Both agencies got marching orders from the National Space Council to update space export controls. The review’s goal was to boost international partnerships but keep national security tight.
They gather industry feedback through surveys, technical advisory committees, and public comment periods on proposed rules. It’s not a perfect system, but at least they’re listening.
The U.S. splits space-related export controls into categories based on sensitivity and military use. Defense articles fall under USML Categories IV and XV, while commercial space items get ECCN classifications under the EAR.
USML Category IV covers launch vehicles and guided missiles that could have military uses. Rockets, engines, guidance systems—they all count. The government treats these as military tech since the same stuff that puts up satellites can deliver weapons.
USML Category XV zeroes in on spacecraft and gear with defense applications. High-resolution remote sensing satellites fit here. These systems are sensitive because they could give foreign nations intelligence capabilities.
Recent tweaks to Categories IV and XV try to make life easier for commercial space companies. The changes clarify what’s a defense article and what’s just commercial. Space tourism and research companies benefit from knowing exactly which items need State Department licenses.
ECCN 9A515 covers spacecraft and space-qualified parts that don’t meet the USML’s strict standards. Commercial satellites, spacecraft buses, and payload gear usually land here. These need Commerce Department licenses, which are less restrictive than State Department ones.
The 600 series ECCNs apply to stuff that shifted from ITAR to EAR. ECCN 9A515 includes spacecraft for commercial comms, earth observation, and scientific research. The classification depends on technical specs and how you plan to use the item.
Companies can usually ship ECCN items to allies with fewer hoops than USML items. Commerce Department licensing is faster. That flexibility helps U.S. space firms compete globally while keeping some controls in place.
Defense articles include anything built for military use or that gives a big military edge. In space, that’s military satellites, classified spacecraft parts, and special launch vehicles. The State Department keeps tight control over these through ITAR.
Defense services cover technical data, training, and help related to defense articles. That means spacecraft design info, launch procedures, maintenance protocols—all that can require a license, even if it’s just a conversation.
It’s not always about how something looks. A satellite camera becomes a defense article if it crosses certain resolution lines. Companies have to check their products against published specs to classify them correctly.
In October 2024, the Commerce Department’s Bureau of Industry and Security (BIS) and State Department’s Directorate of Defense Trade Controls (DDTC) rolled out major updates. The changes remove licensing requirements for some space items to allied nations and shift certain technologies from military to commercial oversight.
BIS put out three rules to bring space-related export controls up to speed. The Final Rule drops license requirements for remote sensing and space logistics spacecraft exports to Australia, Canada, and the UK.
The Interim Final Rule gets rid of licensing for spacecraft components to more than 40 allied nations. That’s a big relief for companies shipping the least sensitive parts.
BIS also expanded license exceptions to cover more NASA cooperative programs. These tweaks help push international cooperation in space tech development.
A new proposed rule, written with the State Department, would move certain defense articles from the U.S. Munitions List to the Commerce Control List. That includes spacecraft able to refuel others and those with autonomous collision avoidance.
These updates came after a long review from the National Space Council, with input from industry surveys, advisory committees, and private sector feedback since 2019.
The BIS proposed rule brings big changes to the Export Administration Regulations for spacecraft and launch vehicles. It suggests tweaks to ECCNs 9A515, 9D515, and 9E515, and adds a new category, 9C515.
A new Commercial Space Activities license exception now covers space agency programs, space tourism, and scientific research. This is a nod to the growing commercial space sector.
The proposed changes line up with recent ITAR updates to keep policies consistent. Companies now have more flexible export options for important commercial space items.
BIS wants public comments on these rules within 30 days of publication. They’re especially looking for ideas on cutting barriers without sacrificing national security protections.
The State Department’s proposed rule would move certain space-related defense articles from USML Categories IV and XV to Commerce oversight. These are items that don’t give the U.S. a big military or intelligence advantage anymore.
Key techs like refueling spacecraft and autonomous collision avoidance systems are set to move from ITAR to EAR control. That lets companies use BIS license exceptions for exports to close allies.
The DDTC rule lines up with BIS amendments to keep the transition smooth. Both agencies coordinated to avoid any regulatory gaps.
Both rules are open for public comment. Industry folks can help shape the final version by sharing feedback on real-world challenges.
Commercial space companies have to juggle a maze of export control rules when working with international partners. The latest regulatory changes are meant to make things easier for trusted allies but still keep a tight grip on sensitive tech.
Commercial space activities have moved way beyond just satellite launches these days. Companies now run space-based manufacturing facilities, handle orbital debris removal, and even set their sights on asteroid mining.
Each of these activities needs a close look under export control rules. The Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) set the standards here.
Space tourism operators have to follow these rules, especially if they use foreign-built parts or train international passengers. Building spacecraft components usually means dealing with controlled technologies, so companies often need licenses before exporting.
Recent rule changes actually removed license requirements for some spacecraft parts sent to over 40 allied countries. That’s a real win for companies like SpaceX and Blue Origin—they can work more smoothly with international suppliers now.
The updated rules also widen NASA cooperative program exceptions. This makes it easier for commercial partners to join in on government missions.
Key regulated activities include:
Spacecraft component manufacturing and assembly
Satellite ground control software development
Space-based refueling and servicing operations
Remote sensing data collection and distribution
Export controls shape how fast American space companies can compete worldwide. Long licensing waits can delay product launches by months, sometimes years.
That lag puts US firms behind competitors from countries with fewer restrictions. The October 2024 rule updates try to fix this.
Now, companies can send certain remote sensing spacecraft to Australia, Canada, and the United Kingdom without needing licenses. The same goes for space-based logistics and servicing spacecraft.
Small commercial space companies probably feel the relief most. Startups don’t always have the resources to wade through complex licensing.
Simpler rules let them focus on innovation instead of paperwork. The Bureau of Industry and Security actually found that 78% of surveyed companies wanted fewer export restrictions for allied nations.
These firms said the current rules made it tough to form partnerships and get into global markets.
Space-based logistics is a rapidly growing field that needs its own export control approach. These services cover on-orbit refueling, satellite servicing, and cargo delivery to space stations.
Autonomous collision avoidance systems have shifted from military control lists to commercial regulations. This move lets companies export these safety-critical technologies more easily to partner nations.
Spacecraft that can refuel others face similar regulatory changes. License exception commercial space activities now apply to a wider range of operations.
Companies that provide orbital assembly services can now work with international clients through streamlined processes. Space-based manufacturing facilities also have fewer hurdles when exporting products back to Earth.
The new rules acknowledge that space logistics almost always involves several countries and companies. A single mission might use an American spacecraft, European parts, and Japanese ground stations.
Updated regulations help make these complicated international operations possible, but still protect sensitive technologies.
New regulations create streamlined pathways for civil space operations using targeted exemptions and specialized licensing. These changes cut red tape for space tourism companies, research groups, and commercial operators, but security standards still apply.
The ITAR Proposed Rule brings in four new exemptions that really change how civil space companies handle export controls. The Official Space Agency Exemption allows defense article transfers within government space programs, but launch vehicles are still excluded.
Space operators get a boost from the Space Activity Exemption, which covers telemetry transmission services and collaborative operations with foreign partners. This exemption kicks in when activities support basic research or help geolocate radiofrequency transmissions, even in emergencies or for cellular communications.
Companies using EAR-controlled spacecraft can use the Defense Articles Incorporated into EAR Spacecraft provision. This exemption makes it easier to export spacecraft with embedded defense-related parts, removing the old conflict between ITAR and EAR classifications.
The exemptions don’t just blanket entire categories—they target specific scenarios. Each one comes with detailed technical requirements and keeps oversight tight for sensitive tech, but they do speed up the process for approved activities.
Export control reforms set up special frameworks for trusted international partnerships and commercial operations. Australia, Canada, and the United Kingdom now get preferential treatment—license requirements are gone for certain spacecraft categories under ECCNs 9A515 and 9E515.
The EAR Final Rule removes licensing hurdles for remote sensing spacecraft and space-based logistics vehicles headed to these allied nations. This change affects about 90 license applications each year, which should save manufacturers and operators a lot of time.
Standards development activities have clearer rules now, thanks to technology exemptions for international spacecraft safety protocols. Companies working on global standards don’t need licenses for software and tech under ECCNs 9D515 and 9E515.
Government space projects get more leeway through clarified License Exception GOV provisions. NASA Space Act Agreements qualify for faster processing, and International Space Station operations keep moving thanks to special Russian launch exemptions.
The Space Tourism and Research Exemption creates dedicated pathways for civilian spaceflight and scientific missions. This rule covers manned spacecraft exports, reexports, and temporary imports when used for space tourism or research.
Spacecraft operators have to keep U.S. person ownership, registration, and operational control to use these exemptions. Flight paths need Federal Aviation Administration approval or the right foreign authorization, so safety oversight stays in place.
Research activities get more flexibility through broader definitions of fundamental research. Universities and research institutions working on space-based studies now face fewer licensing requirements for international projects.
Commercial space tourism companies can use these rules to speed up spacecraft development and form international partnerships. The exemptions help suborbital tourism operators especially, since they often carry international passengers and work with foreign aerospace partners.
Recent export control changes have opened up streamlined licensing paths for space companies working with trusted allies. The biggest updates drop license requirements for certain spacecraft exports to Australia, Canada, and the United Kingdom, while also expanding commercial space exceptions.
The EAR Final Rule removes worldwide license requirements for specific spacecraft and related items sent to Australia, Canada, and the United Kingdom. This affects exports under Export Control Classification Numbers 9A515 and 9E515.
Key affected spacecraft categories include:
Remote sensing spacecraft with electro-optical capabilities
Spacecraft with infrared remote sensing beyond Near Infrared ranges
Radar-equipped spacecraft using certain frequency ranges
Space-based logistics and servicing spacecraft
The Bureau of Industry and Security expects this change will cut about 90 license applications each year. Companies don’t need licenses anymore for technology transfers involving spacecraft development, production, or installation with these three nations.
This exemption shows how closely these countries and the US work together on defense and space. BIS pointed out it hasn’t denied a license application for any of these items to these countries in more than five years.
The EAR Interim Final Rule eases licensing requirements for over 30 allied countries by lowering control reasons from National Security 1 and Regional Security 1 to NS2 and RS2. This mainly affects spacecraft parts and components under ECCN 9A515.x.
Lower-risk spacecraft items now sit in 9A515.y, which means licenses are only needed for exports to China, Russia, and Venezuela. These include things like passenger exercise systems, fire suppression equipment, and facilities for manned spacecraft.
The rule also exempts standards development activities involving spacecraft safety technology. Companies can join in on international standards work without licenses for software and tech under ECCNs 9D515 and 9E515.
Space Act Agreements with NASA now fit under License Exception GOV, making government space project collaboration easier. Special rules allow some exports to Russia for International Space Station launches on short notice.
The proposed License Exception Commercial Space Activities (CSA) would cover certain civil space projects, including space tourism and research. The exception keeps security controls on sensitive parts but aims to boost commercial space growth.
It covers exports and reexports of some spacecraft used in space tourism operations and research. Registration, ownership, and control must stay with US persons, and flight paths need FAA approval.
Four new ITAR license exemptions support civil space activity:
These exemptions set up clear regulatory pathways for nonmilitary space. The Space Tourism and Research Exemption in particular helps the growing commercial space sector by lowering compliance barriers for approved tourism operations while keeping necessary security checks.
Three federal agencies split up control of space export regulations. The Bureau of Industry and Security handles dual-use space tech, the Directorate of Defense Trade Controls looks after military space systems, and NASA coordinates civilian space program needs.
BIS oversees the export of dual-use space technologies through the Export Administration Regulations. These items work for both civilian and military uses.
The Commerce Control List covers satellites, spacecraft parts, and ground control equipment. BIS reviews export license applications for these technologies when companies want to sell them abroad.
Key BIS responsibilities include:
Licensing satellite exports to foreign customers
Controlling spacecraft propulsion systems
Regulating space-qualified electronics and materials
Managing re-export controls for space components
Space companies have to check if their products appear on the Commerce Control List. Things like communication satellites, imaging systems, and navigation equipment usually need BIS licenses.
The agency teams up with other departments to classify items correctly. This helps protect sensitive space tech while still allowing legitimate exports.
DDTC manages military space systems under the International Traffic in Arms Regulations. The United States Munitions List spells out these controlled defense articles.
Military satellites, missile defense systems, and classified space tech all fall under DDTC. Companies need State Department licenses before they can export these items.
DDTC oversees these space-related categories:
Launch vehicles and ballistic missiles
Military communication satellites
Space-based weapons systems
Classified spacecraft technologies
The agency keeps a tight grip on technologies that could boost foreign military power. Space companies working on defense contracts often need DDTC registration and compliance programs.
DDTC works with other agencies to make sure military and civilian systems are classified properly. That way, sensitive defense tech doesn’t end up with the wrong people.
NASA handles civilian space program export requirements and international cooperation. The agency coordinates with BIS and DDTC on space technology transfers.
International Space Station partnerships need NASA’s approval for sharing technology. NASA also oversees commercial crew program export controls.
NASA’s export control role includes:
Approving international space station technology transfers
Managing civilian space program partnerships
Coordinating commercial space company requirements
Overseeing research and development export controls
Space tourism companies often need NASA’s help with certain technologies and launch site access. The agency gives advice on civilian space flight requirements and safety standards.
NASA’s technical know-how helps other agencies classify space tech correctly. That expertise supports good export control decisions for new space industries.
Space companies face a maze of export administration requirements that dictate how spacecraft technology, technical data, and services can move across borders. Export controls demand careful item classification and strict licensing to steer clear of serious penalties.
The export licensing process for space tech starts with figuring out if your spacecraft components, technical data, or services need government approval before leaving the country. The Bureau of Industry and Security (BIS) oversees most commercial space items under the Export Administration Regulations (EAR).
Companies submit license applications that spell out the specific technology, the end user, and how it’ll be used. Reviews usually take 30 to 60 days, but sensitive technologies can drag that out longer.
Key licensing categories for space items include:
Spacecraft systems and subsystems
Propulsion technologies
Navigation and guidance equipment
Ground control software and hardware
Space companies should work with experienced export control attorneys and keep detailed records of all international transactions. Pre-submission consultations with BIS can clarify requirements and help avoid processing delays.
Getting classification right is really the backbone of export control compliance in space operations. Companies need to figure out the Export Control Classification Number (ECCN) for every item they want to export or transfer abroad.
Most space-related items end up in Category 9 (aerospace and propulsion) of the Commerce Control List. If an item doesn’t have an ECCN, it gets labeled as EAR99, which still means you need to pay attention to export rules for some destinations.
Essential documentation requirements include:
Companies have to check all parties against restricted entity lists, like the Denied Persons List and Entity List. They also need to keep documentation for five years and have it ready if the government comes calling.
Violating export controls in the space sector can hit hard, both financially and operationally. Civil penalties can go up to $300,000 per violation or twice the transaction value—whichever stings more.
Criminal penalties? Those can mean fines up to $1 million and even prison sentences up to 20 years if someone willfully breaks the rules. Lately, enforcement actions against space companies have ramped up, and some cases have ended in multi-million dollar settlements.
Common violation triggers include:
Companies can lower their risk by building strong export management and compliance programs. Regular training, internal audits, and even coming forward voluntarily about mistakes show good faith and can help reduce penalties.
Space export controls zero in on certain advanced technologies that could impact national security or foreign policy. The focus lands mostly on remote sensing, spacecraft propulsion, and specialized software that makes crucial space operations possible.
Remote sensing spacecraft get the strictest export controls because of their dual-use potential. Rules especially target spacecraft with electro-optical remote sensing, mainly those with clear apertures between 0.35 and 0.50 meters.
If a system works past Near Infrared—into Short-Wave Infrared, Mid-Wave Infrared, or Long-Wave Infrared—it needs worldwide licenses. These features let spacecraft do detailed Earth observation, which can be useful for both business and military.
Radar remote sensing tech gets extra scrutiny, too. Systems like Active Electronically Scanned Arrays, Synthetic Aperture Radar, and Inverse Synthetic Aperture Radar in certain frequency ranges need licenses for most countries.
Key Controlled Remote Sensing Technologies:
Radiofrequency transmission gear faces controls when you build it into spacecraft. Restrictions cover telemetry systems, communication arrays, and navigation equipment that could allow precise tracking or eavesdropping.
Launch vehicles sit at the top of the list for strict export controls, mostly because of their military uses. Most launch vehicle tech falls under ITAR, not EAR.
Manned spacecraft tech also faces targeted controls, trying to balance the boom in space tourism with security. Any spacecraft made for logistics, assembly, or servicing other spacecraft needs worldwide licenses.
Some new rules now carve out exemptions for space tourism. The Space Tourism and Research Exemption lets certain manned spacecraft exports go through if U.S. persons keep ownership and control.
Controlled Spacecraft Components:
Electric propulsion tech—like plasma and ion thrusters—faces export restrictions, along with their power controls. Special control moment gyroscopes designed for spacecraft also need licenses for most international deals.
Mechanisms that hold down or release satellites—clampbands, adapters, dispensers—are classified as controlled commodities.
Spacecraft software doesn’t get a free pass. Export controls cover both commercial and defense software. Space Situational Awareness analysis software even joined the controlled list under recent updates.
Tech for building, producing, and installing spacecraft needs licenses for most international transfers. That covers manufacturing, testing, and maintenance for controlled spacecraft.
Key Software Controls:
Materials and coatings that help spacecraft hide get new export restrictions. These include treatments that cut down radar, optical, ultraviolet, and infrared detection.
There’s an exemption for standards development work, so U.S. companies can help set international spacecraft safety standards. This covers tech and software in certain ECCN categories, as long as it’s for global safety protocols.
The Commerce Department keeps a reserved classification system for parts that need tighter licensing. These items keep NS1 and RS1 controls, while less sensitive components get downgraded to NS2 and RS2.
Export control rules for commercial space are changing fast. Agencies try to balance national security with the need to let the industry grow. Lately, the focus has shifted to streamlining things for commercial operators but tightening the reins on sensitive tech and global partnerships.
Regulatory changes have a real impact on how commercial space companies invent and launch new tech. The Bureau of Industry and Security now demands more export control for satellite parts and spacecraft systems.
Companies are running into tougher licensing requirements for dual-use tech. That includes advanced propulsion systems, satellite comms gear, and navigation tech. Startups, especially, feel the pinch.
Key regulatory impacts include:
The ITAR framework keeps changing to fit commercial space. Some commercial satellites moved from the munitions list to the commerce control list, which lightens the load for routine commercial space activity.
New licensing categories now cover commercial space tourism and cargo services. These rules acknowledge that civilian space operations really are a different animal from traditional aerospace.
Export controls make international space partnerships tricky. Companies have to juggle multiple regulatory systems when working with foreign partners or customers.
The current rules limit tech sharing with certain countries. Companies really hit a wall when their partners come from places labeled as countries of concern. These limits affect satellite manufacturing deals and launch agreements.
Partnership considerations include:
European and Asian markets offer both opportunity and headaches. Companies looking to expand globally have to structure deals carefully to stay compliant but also stay competitive.
Some licensing exceptions help keep business moving. These let companies handle routine maintenance, customer training, and support under certain conditions.
Regulators are working on new rules for up-and-coming space tech. This includes controls for in-space manufacturing, asteroid mining gear, and next-gen propulsion.
Artificial intelligence in spacecraft is drawing more attention from regulators. Export controls might soon cover AI-powered navigation, autonomous docking, and machine learning for space ops.
The rules for commercial space tourism will probably keep evolving. Agencies want to balance passenger safety with export compliance for international customers.
Expected regulatory developments:
Foreign policy is playing a bigger role in export control decisions for space. Geopolitical tensions shape tech sharing deals and international space cooperation efforts.
Regulators are moving toward risk-based enforcement. They’re focusing on the riskiest activities and trying to ease up on routine operations. Companies can expect oversight that matches what they’re actually doing and who they’re working with.
Export control rules can get pretty complicated for aerospace companies and defense contractors working with global partners. Space tech exports need strict licenses for everything from satellite parts to launch services, under both commercial and defense regulations.
The International Traffic in Arms Regulations (ITAR) sets the rules for exporting defense-related space tech. ITAR covers launch vehicles, spacecraft, satellites, and all the related technical data under the United States Munitions List (USML).
The Export Administration Regulations (EAR) handle dual-use items with both commercial and military uses. EAR controls things like high-powered computers, encryption software, and some satellite parts that don’t fall under ITAR.
The Office of Foreign Assets Control (OFAC) enforces economic sanctions that ban exports to certain countries and entities. Companies have to check all international partners against OFAC’s Specially Designated Nationals list before doing any export business.
Sanctions can mean a total ban on exports to some countries, no matter what the tech is. Russia, Iran, North Korea, and a few others face blanket restrictions on space tech transfers.
Some sanctions target specific companies or organizations in the space sector. These rules stop U.S. companies from giving satellite services, launch capabilities, or technical help to those entities.
Secondary sanctions go further, hitting third-party countries that work with sanctioned groups. Foreign companies using U.S.-origin space tech have to comply or risk losing access to American suppliers.
Technical Assistance Agreements (TAAs) let companies transfer ITAR-controlled tech data and services to foreign partners, but they need State Department approval and have strict security requirements.
Manufacturing License Agreements (MLAs) allow foreign production of ITAR-controlled space tech. The process involves detailed tech transfer plans and ongoing compliance checks.
Export licenses under EAR require government sign-off for dual-use space tech transfers. The timeline can run from a few weeks to several months, depending on where it’s going and how sensitive the tech is.
ITAR covers military space systems—think reconnaissance satellites, military comms, and missile tech. The State Department’s Directorate of Defense Trade Controls handles ITAR licensing and compliance.
EAR manages commercial space tech that could have military uses. The Commerce Department’s Bureau of Industry and Security controls things like commercial satellites, space-rated electronics, and some propulsion systems.
The line between ITAR and EAR decides who issues the export license. Recent updates moved some commercial satellites from ITAR to EAR, making exports easier for commercial space companies.
ITAR registration brings a lot of compliance headaches for small space companies. Registration fees, annual reports, and security requirements can really add up for startups.
Foreign investment rules limit access to global capital. ITAR-registered companies have to go through CFIUS review if foreign ownership goes over certain limits.
Deemed export rules restrict foreign nationals’ access to controlled tech. Companies need licenses before they can hire foreign engineers or let international staff work on controlled space projects.
Supply chain mapping helps companies spot every controlled item and tech transfer in these complicated space projects. Teams need to keep an eye on U.S.-origin content hiding inside foreign-made components to figure out if export controls apply.
Export compliance programs give companies a way to set up internal controls for spotting, reviewing, and licensing controlled exports. Good programs usually cover employee training, clear steps for classifying technology, and regular compliance audits.
Some companies form strategic partnerships with established aerospace contractors, which lets them tap into existing export licenses and compliance systems. Joint ventures or teaming up with others can make compliance less of a headache for each company and open up more international opportunities.
