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ARTICLE · 11 MAY 2023

DDTC Revises USML Category XI

Squire Patton Boggs LLP
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On April 27, 2023, the U.S. Department of State published an Interim final rule and request for comments to amend the International Traffic in Arms Regulations (ITAR) to "remove...

United StatesInternational Law
Trade Practitioner
Trade Practitioner

On April 27, 2023, the U.S. Department of State published an Interim final rule and request for comments to amend the International Traffic in Arms Regulations (ITAR) to "remove from U.S. Munitions List (USML) Category XI certain high-energy storage capacitors and to clearly identify the high-energy storage capacitors that remain in USML Category XI."

In this rule, the Department is removing certain storage capacitors from the ITAR list, due to technology progression that has rendered them "extensively integrated into commercial applications" and "widely available internationally without multilateral export restrictions." Such high-energy low-voltage storage capacitors have broad commercial application, including in Wi-fi routers and civil aviation aircraft transponders. As such, they do not provide a critical military or intelligence advantage. Accordingly, the interim final rule adds a 125 V criterion for high-energy capacitors described on the USML. The interim

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