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It's Only Common Sense: Thank You, IPC

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Kudos to IPC for trying to raise awareness when it comes to International Traffic in Arms (ITAR) regulations. The association recently hosted a workshop with the country’s leading defense contractors in an attempt to educate them about ITAR in terms of PCBs.From the press release that appeared on PCB007:Domestic printed circuit board manufacturers have sounded an alarm that defense industry confusion over ITAR’s treatment of printed circuit boards is undermining national security,” said IPC President and CEO John Mitchell. “IPC is grateful for the opportunity to partner with federal officials in workshops like this to clarify current and proposed export control regulations.Yes, way to go IPC and John Mitchell. This is one of the first times in a long time that the IPC has stood up for PCB fabricators and the best indicator I’ve seen that there’s a new sheriff in town.

The story goes on to say:

Today’s workshop and the broader educational campaign of which it is a part were organized by IPC to address concerns that some defense contractors source printed circuit boards for ITAR items from non-ITAR facilities. Although not listed explicitly on the United States Munitions List (USML), the export of printed circuit boards and their designs are regulated by ITAR as specifically designed parts and components.

And there you have it, in black and white. Let’s not have any more of this “confusion” by defense contractors and, more specifically, their contract manufacturers (CMs) that have played fast and loose with regulations, hiding behind any “fuzziness” they could muster so that boards could be built by non-ITAR factories. Circle the wagons, boys; the regulations have been specified. The PCB is covered by ITAR as a specifically-designed component. ITAR cheaters can no longer hide behind their famous ill-used statement that the PCB is too far down the supply chain to be covered by ITAR. Those who wrote the regulation, those who enforce the regulation, and the industry's own governing body have now officially declared that the PCB is covered by ITAR.

The story continues:

As Brent Grazman, vice president of quality, Viasystems explained, “It is important for our customers to pay attention to export compliance issues in their supply chain in addition to those related to their end items. This starts with clear communication about purchases such as PCBs destined for use in ITAR covered products.” Grazman suggests that defense contractors “ensure that their PCB supplier has developed a rigorous compliance system to protect from supply disruption and possible enforcement activity.”

In plain English, you’d better make sure that your PCB suppliers are fully ITAR-compliant or suffer the consequences when they are shut down for non-compliance and you are fined for using them.

If you are a military contractor, or one of their CMs, you had better heed this advice. You had better be using ITAR suppliers because we are watching you and we will turn you in.

I have spoken to a number of board shops in this country that are fully-compliant ITAR suppliers and they have told me in no uncertain terms that if they lose defense business to a non-ITAR-compliant PCB supplier they are going to turn them in and they are going to turn their would-be customer in as well.

One representative from an ITAR shop told me that when one of their long-time customers turned over their business to a CM and told the CM to buy from his shop, the CM turned around took the ITAR requirement off the prints and went to non-ITAR PCB vendors. The representative familiar with the project immediately called the OEM to see if something had changed and why he was asking. The OEM was shocked and pulled the job from the CM.

I think that we're going to be seeing more of this. Most American ITAR PCB fabricators have no compunction in turning anyone in who is not going to comply with ITAR--they feel completely justified in doing so. They look at it as a move that will not only protect their livelihood, but defend the country as well.

Once again, I applaud the IPC and John Mitchell for taking this step and hope that it is only the first of many such steps to assure that we protect the segment of the American PCB market that rightfully belongs to the American PCB industry.

It’s only common sense.