Export Control Awareness

Export Control Awareness (cross-cutting/export-control/export-control-awareness)

Use when an aerospace engineering task touches data or items that may be export controlled: sharing a specification with a foreign collaborator, publishing a report, releasing design data to a vendor, or starting work on propulsion, guidance, sensor, or materials topics. The skill screens the topic for red flags and returns a conservative verdict class with handling guidance. It is a screening aid, not a legal opinion: every verdict must be confirmed by the organization's trade compliance office before any release of controlled data.

Domain quick reference

• Jurisdiction split: items described by the US Munitions List (USML, 22 CFR part 121) are defense articles under ITAR. Items under EAR jurisdiction are described by the Commerce Control List (CCL, 15 CFR 774) or fall to EAR99, the default for items not elsewhere specified.
• USML categories that matter for aerospace: IV (launch vehicles, guided missiles, ballistic missiles, rockets, torpedoes, bombs and mines), VIII (aircraft and related articles), XII (fire control, laser, imaging and guidance equipment), XIII (materials), XV (spacecraft and related articles), XVIII (directed energy weapons), plus the catch-alls XVII and XXI. Category XIX is reserved.
• EAR 600-series: export control reform moved most defense articles from the USML to 600-series ECCNs. Aerospace examples: 9A610 (military aircraft), 9A619 (military gas turbine engines), 9D610 and 9E610 (software and technology for those), 8A609 (marine gas turbine engines), 0A606 (military ground vehicles). Verify each ECCN against the current regulation.
• EAR99: the default classification for items with no CCL entry. EAR99 is not a free pass: end-use and end-user screening still applies, and supporting a restricted end use or end user is prohibited.
• Technical data (ITAR): information required for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification of defense articles, including blueprints, drawings, photographs, plans, and instructions. General scientific and mathematical principles commonly taught, and public domain information, are excluded.
• Public domain (ITAR 22 CFR 120.34, EAR 15 CFR 734.7 through 734.8): information published and sold without restriction, published patents, unlimited-distribution conference material, and fundamental research results. The fundamental research exclusion is lost when the research agreement restricts publication or sharing.
• Deemed export: releasing technical data or technology to a foreign person inside the US is treated as an export to their country of nationality and may require authorization.
• Red-flag topics (screened by flag_restricted_topic): turbine blade alloys and high-temperature materials, propulsion technology, missiles and rockets, controlled sensors and seekers, avionics and navigation, low-observable design, spacecraft, unmanned aerial systems, radiation-hardened electronics, cryptographic items, hypersonics, directed energy, specialty composites, energetic materials, fire control, military aircraft and engines, and defense services. A red flag means stop and verify, not "controlled".

Workflow

1. Describe the item or data set in one free-text string: what it is, what it is made of, and what it does.
2. Screen the topic: flag_restricted_topic(item) returns matched red flags with reasons. Any hit is a stop-and-verify signal.
3. Establish the information basis: is_public_domain(source=...) with source one of published, textbook, patent, conference, fundamental-research, unpublished. Pass restricted_agreement=True when a research agreement restricts publication or sharing.
4. Run the tree: export_decision_tree(item, audience, purpose, ...) with audience one of us-person, foreign-person, public, and purpose one of internal-engineering, sharing, publication, teaching, fundamental-research, procurement, foreign-release. The verdict is defense-article, dual-use, public-domain, or not-controlled, with jurisdiction, risk, red flags, and actions.
5. Follow the actions and escalate: never release controlled data without authorization, and never mark anything as compliant on your own authority.

All functions validate their inputs and raise ValueError on unknown audience, purpose, source, or USML category values.

Worked example

An engineer wants to share a single-crystal turbine blade alloy specification with a foreign collaborator.

from export_control_logic import export_decision_tree, flag_restricted_topic

item = "single crystal turbine blade alloy for the high pressure turbine"
print(flag_restricted_topic(item))
result = export_decision_tree(
    item=item,
    audience="foreign-person",
    purpose="sharing",
    ear_600_series=True,
)
print(result["verdict"], result["jurisdiction"], result["risk"])

Output: the topic flags "turbine blade alloys and high-temperature materials", and the tree returns verdict dual-use, jurisdiction EAR, risk medium, with a deemed export action: releasing the data to a foreign person inside the US is a deemed export to their country of nationality, so authorization is required before sharing.

A second example: a lift coefficient formula from a published textbook classifies as public-domain (is_public_domain(source="textbook") returns True), because published textbooks are public domain information.

Pitfalls

• Treating a red-flag topic hit as a verdict: flag_restricted_topic is a stop-and-verify signal, not an automatic denial, and a clean topic screen does not by itself clear a release.
• Marking anything as compliant on your own authority: the tree returns jurisdiction, risk, and actions, but releasing controlled data still requires authorization, and only the compliance office can certify anything.
• Forgetting the deemed export rule: sharing technical data with a foreign person inside the US is a release to their country of nationality and needs the same authorization as an export.
• Assuming "published" implies public domain: only the listed sources (published, textbook, patent, conference, fundamental-research) classify as public domain, and unpublished results under a restricted research agreement do not.
• Passing unknown audience, purpose, source, or USML category values: the functions raise ValueError, so mis-typed inputs fail loudly instead of defaulting to a permissive verdict.
• Skipping the handling checklist before a release: the checklist in assets/export-handling-checklist.md must be worked through and the verdict confirmed by the trade compliance office first.

Verification checklist

Use the handling checklist in assets/export-handling-checklist.md and verify before committing any release:

• Topic screened with flag_restricted_topic, red flags recorded.
• Public domain basis checked with is_public_domain; restricted agreement status confirmed with the research office.
• Decision tree run with the real audience and purpose; verdict, jurisdiction, and risk recorded.
• Foreign-person releases checked for deemed export implications.
• Verdict confirmed by the trade compliance office before release.
• No controlled data exported or shared without authorization.
• Nothing marked or represented as compliant or certified except by the compliance office.

Scripts and references

• scripts/export_control_logic.py - pure Python logic module: classify_export_status(), is_defense_article(), is_public_domain(), flag_restricted_topic(), export_decision_tree().
• scripts/test_export_control.py - offline contract test (stdlib unittest, deterministic): turbine blade alloy topics return a restricted red flag, published textbook formulas classify as public-domain, and invalid inputs raise ValueError. Run with python3 scripts/test_export_control.py.
• references/itar-ear-overview.md - regulatory overview: USML category table, EAR 600-series examples, technical data and public domain definitions, fundamental research exclusion, deemed exports, and the red-flag topic table with citations.

Related skills

• cross-cutting/documentation/engineering-report - report writing that must carry export control review records.
• cross-cutting/documentation/engineering-margins - engineering margin analyses whose results may be technical data.
• cross-cutting/data-sources/aeronautical-data-sources - sourcing aeronautical data, some of which is restricted.

Behavior contract (gate 3)

The export-classification logic (topic red flags, public-domain basis, and the export decision tree) is exercised by the gate 3 contract test: scripts/test_export_control.py against scripts/export_control_logic.py (stdlib unittest, offline). Run:

python3 scripts/test_export_control.py