Why ITAR Compliance is Critical for EMP/HEMP Filters

 TSS USA Manufacturing
Why ITAR Compliance is Critical for EMP/HEMP Filters

Russia and China are actively developing EMP weap-
ons designed to disable even protected electrical
systems and infrastructure. An EMP component of a
nuclear blast can be destructive toward electronics
over a much wider area than a nuclear blast. Nuclear
weapons detonated in space can emit a HEMP, which
can affect ground-based electrical systems, aircraft,
and vehicles. HEMP/EMP filters and all information
pertaining to these defensive items are covered un-
der the USML category XVIII(e) and must be handled
carefully. In 2017, TSS requested a “COMMODITY JU-
RISDICTION DETERMINATION” for High Altitude Elec-
tro-Magnetic Pulse Filters. TSS cited a few part num-
bers as references. The U.S. Department of State has
determined that filters and related information are
subject to the jurisdiction of the Department of State
under ITAR (22 CFR 120 through 130). Filters and re-
lated information are defense articles and require a
license or other form of approval per ITAR regulations
for any export or temporary import of filters or related
information.

Of major concern are the current threats these pulses
pose to modern society, a society that is increasingly
dependent on microelectronics for so many functions.
In this respect, recovery times could range from months
to over a decade. Regrettably, only a scant few orga-
nizations have spearheaded ways to protect critical
and sensitive electronic systems from IEMI and EMI
threats. The good news is that new EMI EMP/HEMP or
IEMI filters have been developed. These can protect
specific electrical assemblies or sub-assemblies from
IEMI threats to the point where susceptible electrical
systems can not only survive but suppress harmful EMI
episodes.
The question then arises, what standards must such
filters meet? Governmental, military, and recent-
ly IEC have set specific standards for filters capable
of withstanding known IEMI threats, mainly nuclear
EMPs, and high-altitude nuclear HEMPs. To maintain
compliance, a company must be ITAR registered and
each transaction requires a specific license that the
ITAR-registered company working on the program
must create.
High Altitude Electro-Magnetic Pulse (HEMP) and Elec-
tro-Magnetic Pulse (EMC) are becoming increasingly
critical to protecting US critical infrastructure. As noted,
these filters are categorized as defense articles. Filters
or related information to be shared with any foreign
national or foreign company. U.S. suppliers working
with foreign nationals—whether customer or suppli-
er—should ensure that they are compliant with all ITAR
regulations and when necessary, obtain the proper
licenses. Penalties for violating ITAR regulations are
too severe to not take the steps to ensure compliance.

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