Two lists, two agencies
The International Traffic in Arms Regulations (ITAR) control defence articles. The US State Department's Directorate of Defense Trade Controls administers them, and the items they cover are on the United States Munitions List (USML). Spacecraft are Category XV.
The Export Administration Regulations (EAR) control commercial and dual-use items. The Commerce Department's Bureau of Industry and Security administers them, and controlled items are listed on the Commerce Control List (CCL), each under an Export Control Classification Number (ECCN).
| ITAR | EAR | |
|---|---|---|
| Agency | State Department (DDTC) | Commerce Department (BIS) |
| Law | 22 CFR 120–130 | 15 CFR 730–774 |
| List | US Munitions List (USML) | Commerce Control List (CCL) |
| Covers | Defence articles and services | Commercial and dual-use items |
| Satellites | USML Category XV, the most capable systems | ECCN 9A515, most commercial spacecraft |
| Lowest level | None: if it is listed, it is controlled | EAR99: subject to the EAR, usually no licence |
Where satellites moved in 2014
Until 2014 nearly every satellite and satellite part was a defence article under ITAR. US export control reform moved most commercial spacecraft and their parts to the EAR, into the new ECCN 9A515, with effect from November 2014. Only the most capable systems and parts stayed in USML Category XV.
Both agencies published further revisions in October 2024. The lists change, so always classify against the current text.
Where star trackers fall
Star trackers are split by performance. USML Category XV(e)(16) keeps under ITAR the star trackers accurate to 1 arcsecond (1σ) or better that keep working at angular rates of 3.0°/s or more. Other star trackers are generally controlled under the EAR, in ECCN 7A004, or 7A104 for missile-related items.
That line matters for agile satellites. A US-made star tracker that is both precise and able to track through fast slews is a defence article, with all the licensing that brings for a buyer outside the US.
The ITAR-free star trackerWhat ITAR-free means
ITAR-free means an item is not a US defence article and contains none. ITAR follows US defence content into foreign products: a foreign-built unit that includes an ITAR-controlled part is itself controlled. A star tracker designed and built outside the US, with no US defence articles inside, carries none of that.
For a satellite builder outside the US, ITAR-free parts remove the slowest licensing step, and the retransfer restrictions that follow a US defence article through its whole life.
What ITAR-free does not mean
It does not mean free of all export controls. A foreign product can still be subject to the EAR when it contains more than a de minimis share of controlled US-origin content: typically 25%, and less for some destinations and items. The exporting country's own rules also apply. In India, that is the SCOMET list, administered by the Directorate General of Foreign Trade.
That is why we say our star camera is ITAR-free, and never that it is free of export controls.
Before you buy
Ask each supplier for the export classification of what you are buying, meaning the USML category or the ECCN, and the country of origin. Have your export-compliance adviser check it against your destinations. This guide is general information and is no substitute for legal advice.
Our ITAR-free star tracker