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If the aperture is below 0.50m, it should be subject to US Department of Commerce’s Commerce Control List (CCL) of dual-use technologies governed by the Export
by O__________O 4y ago
If the aperture is below 0.50m, it should be subject to US Department of Commerce’s Commerce Control List (CCL) of dual-use technologies governed by the Export Administration Regulations (EAR) — not ITAR. How big is the aperture? Did something else qualify it as being under scope of ITAR?
SOURCES:
https://spacepolicyonline.com/news/satellite-export-controls-get-another-update-jwst-no-longer-under-itar/ https://spacepolicyonline.com/news/satellite-export-controls...
https://www.spiedigitallibrary.org/proceedings/Download?urlId=10.1117%2F12.2535945 https://www.spiedigitallibrary.org/proceedings/Download?urlI...
* (might try reaching out to author’s of paper above to see if they have any suggestions)
Personally, I would not make to much of how people respond to you independently trying to complete paperwork. My guess is it’s more likely related to any non-consumer system that requires paperwork not wanting to deal with non-professionals and/or give legal advice.
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Unrelated, do you have a breakdown of the SatComm expense by type product/vendor and/or utility fees/rates and expected utilization?