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ITAR Requirements for PCB ENIG Providers

Close up photo of a printed circuit board

Before making your new invention commercially available, take care to learn of the applicable legal requirements, specifically ITAR regulations, that you must fulfill. 

Some people will advise you to simply find these requirements on the federal government’s website, but it’s not that simple. The rules are complicated and can be changed regularly making it easy to make costly mistakes. This blog will therefore explain ITAR requirements in detail, specifically to help PCB ENIG providers figure out what aspects of ITAR are necessary for their work. Violating these rules can result in severe penalties like fines and imprisonment for up to 10 years.

What is ITAR?

ITAR stands for the International Traffic in Arms Regulations. These are important rules the U.S. government issues to control how defense products can be imported and exported. The U.S. Department of State’s Directorate of Defense Trade Controls (DDTC) makes sure everyone follows these rules and keeps a list called the United States Munitions List (USML), which outlines what items are under this control

Companies and individuals that manufacture, sell, or distribute these defense products must comply with ITAR requirements. This often involves obtaining licenses for the export or import of controlled items, as well as implementing strict security measures to prevent unauthorized access to sensitive information.

ITAR and PCB Manufacturing

While PCB (Printed Circuit Board) manufacturing itself might not be inherently defense-related, certain aspects of PCB production, especially those involving specialized materials or technologies, can fall under ITAR if they are intended for use in defense or military applications. 

ITAR Requirements that PCB ENIG Providers Need To Follow

Soldiers sitting beside containers and using computers.
  • Registration With DDTC: All PCB ENIG providers that work on items that have been identified as ITAR-controlled must register with DDTC within the U.S. Department of State. The registration is mandatory for all entities involved in the manufacturing, exporting, and brokering of defense articles and services covered under ITAR. 
  • Identification of ITAR-Controlled Items: Providers must have mechanisms in place to identify any defense articles or technologies that fall under ITAR regulations. This includes ensuring that any products, designs, or technical data related to defense applications are appropriately classified and controlled. 
  • Restricted Access to ITAR-Controlled Information: ITAR regulations require strict control over access to ITAR-controlled information. PCB providers must implement security measures to ensure that only authorized personnel have access to ITAR-related data, documents, or facilities. 
  • Secure Data Management: Practices must also be in place to protect ITAR-controlled technical data and information. Sensitive data must be encrypted on top of having restricted access controls and secure storage mechanisms. 
  • ITAR Training and Awareness: All employees involved in ITAR-controlled activities must receive appropriate training and awareness programs. The training should cover the requirements of the ITAR regulations, including the classification of defense articles, handling of technical data, and reporting obligations. 
  • Record Keeping and Documentation: PCB ENIG providers must maintain accurate records and documentation related to ITAR-controlled activities. This includes records of exports, transfers, and disclosures of defense articles or technical data as well as licenses or authorizations obtained from the DDTC. 
  • Compliance Monitoring and Auditing: Regular compliance monitoring and auditing processes like internal audits, self-assessments, or third-party audits must be done to identify and address compliance issues. 
  • Reporting Obligations: Providers must comply with the ITAR reporting obligations such as reporting any unauthorized disclosures, transfers, or diversions of ITAR-controlled items or technical data to the appropriate authorities. 
  • Export Control Classification Number (ECCN) Determination: ECCNs must be accurately determined to help identify whether items are subject to ITAR regulations or other export control regimes such as the Export Administration Regulations (EAR).

How We Can Help You

At Alternate Finishing, Inc. we are an ITAR-registered finishing company that can help you meet your metal plating needs all while ensuring that your product meets the ITAR requirements. We will help you develop robust and cost-effective finishing solutions, advise you on how to improve existing designs as your products evolve, and help you troubleshoot and investigate any design failures. If you are ready to get your metal plating project done, contact us or request a quote today.

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