The State Department’s Directorate of Defense Trade Controls recently eased export controls on certain capacitors for six months.

DDTC has determined that it is in the security and foreign policy interests of the U.S. to facilitate commercial uses of certain capacitors when integrated into any item not described on the U.S. Munitions List (e.g., certain items used in energy exploration and commercial aviation). Accordingly, DDTC has suspended section 120.11(c) of the International Traffic in Arms Regulations with respect to capacitors described in USML Category XI(c)(5) that have a voltage rating of 125 volts or less and have been integrated into, and included as an integral part of, any item not described on the USML. Such articles are licensed by the Department of Commerce when integrated into, and included as an integral part of, items subject to the Export Administration Regulations.

This suspension is valid for the period Nov. 21, 2022, to May 21, 2023, or until it is terminated by notice, whichever occurs first. DDTC states that violations of the terms and conditions of any State Department export license issued prior to this period remain a violation of the Arms Export Control Act and that industry members are “strongly encouraged” to disclose unauthorized exports, reexports, retransfers, or temporary imports of defense articles, including the subject capacitors, that occurred prior to this temporary suspension.

DDTC adds that capacitors described in USML Category XI(c)(5) remain subject to ITAR controls in all other circumstances, including as stand-alone articles. In addition, the export, reexport, retransfer, or temporary import of technical data and defense services directly related to all defense articles described in USML Category XI(c)(5) remain subject to the ITAR. 

For more information on this and other export control issues, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.

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