Arlington, Va. – The Aerospace Industries Association (AIA) submitted comments to key government agencies recommending updates to space-related export controls to make U.S. space technology more competitive on the global stage.
“Modern export controls are essential in advancing U.S. global space leadership. These efforts by the Department of State and the Department of Commerce to modernize space-related export controls are critical for U.S. companies to maintain their edge is space technology that supports our national security and foreign policy goals,” said Dak Hardwick, AIA’s Vice President of International Affairs. “AIA’s comments further strengthen these proposed changes and we are eager to continue collaborating with the Departments of State and Commerce to ensure the regulations are clear, consistent, and effective in supporting U.S. interests.”
“As the U.S. space industrial base continues to expand and technological innovation accelerates, AIA, on behalf of the U.S. space industry, remains committed to advancing the space enterprise while protecting national security and enabling commercial space interests abroad,” said Steve Jordan Tomaszewski, AIA’s Vice President of Space Systems.
Key recommendations provided to the Directorate of Defense Trade Controls (DDTC) and the Bureau of Industry and Security (BIS) include:
- Ensure controls accurately reflect Missile Technology Control Regime (MTCR) commitments and determinations: As written, DDTC’s proposed rule controls technology that is no longer listed in the MTCR’s technology annex is not controlled by other MTCR partner nations, or includes language that may create confusion among industry regarding MTCR determination of articles. Attention should be placed on unmanned aerial vehicle (UAV) rocket propulsion systems, “specially designed parts and components” of separation systems and staging mechanisms, and UAV airborne launching systems.
- Define terms clearly in the U.S. Munitions List (USML) and § 121.0 to ensure they reflect widely recognized understandings of space technology: Proposed definitions of terms provide clarity and support interpretation and adoption from industry. This effort to provide clear definitions should be further expanded and reflect the A&D industry’s understanding of space technology and spaceflight.
- Provide clarity on proposed USML changes to avoid misinterpretation: Given the scope of changes, industry would benefit from further review on certain USML paragraphs to ensure the intended controlled technology is clearly stated and understood. Misinterpretation may be avoided through minor reclassifications, further defining controlled articles, and ensuring references are aligned and clear.
In 2023, the U.S. aerospace and defense industry exported $135.9 billion of goods in 2023 and serves as a symbol of U.S. global trade leadership and technological innovation. The rate of change in new technology is steep, especially in space, and the U.S. aerospace and defenseindustry continues working with the DDTC to ensure that the most critical technology is safeguarded for national and economic security.
Find the summarized comments here.
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