PCB007 Magazine

PCB-Oct2014

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28 The PCB Magazine • October 2014 ITAR-controlled defense article into which it will be installed. Printed boards are essential to many defense systems. Specifically and uniquely designed for each and every one of those systems, printed boards are used to mechanically support and elec- trically connect electronic components. Printed board designs reveal critical information about the board as well as about the devices for which they are designed. Accordingly, clear and appro- priate protection of printed board designs for USML items is needed to safeguard, from U.S. ad- versaries, inherently sensitive information about both PCBs and their associated U.S. weaponry and military equipment. From the designs for printed boards to the boards themselves, significant information can be learned about the workings of the item for which the board is designed. For example, PCBs designed for IED jammers help determine radio frequency and range capability. Ac - cess to the design of these PCBs would provide an understand- ing of the jammer and how to circumvent it, leading to greater U.S. casualties during military engagements. In sum, printed boards— the central nervous systems for all electronics—hold valuable and specific information about the workings of the underlying defense articles themselves. Com - panies with access to the designs of printed boards for defense articles thereby also have access to sensitive information about con- trolled technologies. This exposes these technolo- gies to malicious intrusion by U.S. adversaries that may destroy the reliability of U.S. weaponry and other critical defense equipment. Failure to prop- erly secure the information embedded in printed boards that are custom-designed for defense ar- ticles could result in a breach of national security, theft of critical defense-related intellectual prop- erty and allow for reverse engineering of critical defense systems. The Need for Export Control Reform In August 2009, the Obama administration announced a comprehensive review of the U.S. export control regime in an effort to address long - standing concerns that the current system fails to adequately safeguard both national security and economic competitiveness. For more than 60 years, U.S. export controls have suffered a patchwork of fixes with new re- quirements and cumbersome rules resulting in inefficiency, poor security and lost business. An increasing number of global companies are purchasing products outside the U.S. because of the onerous U.S. export controls system. Oth- ers are taking actions such as ceasing to design electronics using U.S.-made products or stopping work with U.S.-based companies altogether. U.S. regulations control the export of both de- fense and dual-use items (i.e., items that can be used for both commercial and military purposes). Electronics, including certain printed boards, are examples of potentially regulated exports. Con- trols on ITAR-covered electronics also extend to the associated intellec- tual property (IP), such as chemi- cal formulas, purchase orders containing specifications, and printed board artwork. The administration's am- bitious plans call for the cur- rent outmoded regime to be replaced with a single-tiered control list, a single agency to administer controls, a single enforcement agency, and a uni- form, multiagency IT structure to streamline licensing approvals. Fully achieving the administration's vision will entail passage of legislation by Congress, but the admin- istration has moved aggressively to accomplish that which is within its authority, including a re- write of USML categories. IPC is a supporter of efforts to modernize and streamline export control regulations. The current export control system neither adequately protects national security, nor facilitates the export op- portunities needed to grow the economy. Most importantly, IPC has advocated that the admin- istration must use the opportunity provided by the reform of the nation's export control rules to clarify the frequently misunderstood regulatory treatment of printed circuit boards that underpin critical defense technologies. NEW REGULATIONS CLARIFY U.S. ExPORT CONTROLS FOR DEFENSE PCBS continues The current export control system neither adequately protects national security, nor facilitates the export opportunities needed to grow the economy. " "

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