Producing reliable PCBs for electronic defense applications means producing PCBs with high technical performance with a tolerance for extreme harsh environments. There are also several rules and regulations that the product and manufacturing process need to be compliant to. We have talked to some of our NCAB experts regarding what to think about when producing reliable PCBs for the defense industry.
When buying and manufacturing printed circuit boards for the defense industry, everyone in the entire supply chain needs to follow a number of rules, regulations and laws in order to get permission to do this. USA, EU and NATO have different rules, while some are applicable to several markets. Included in this are also different types of export licenses that are needed to export printed circuit boards to different countries. It is not only the compliance to the regulations that needs to be covered, the set up within the organization is equally important. It´s necessary that the PCB supplier is large enough to have the possibilities and knowledge to support and control the factories and all parties involved.
What is export control regulations?
“Export controls is a far-reaching topic that covers many things. The scope of these laws can be very broad and may restrict and regulate more than just the technical data. Everyone in the supply chain is responsible for complying with laws and regulations that govern export controls, and responsible for knowing that your customer and your supplier are legally authorized to have access to the export-controlled item or service. In order to protect your company’s and your customer’s interests, it is important to partner up with a supplier that understands and adheres to export control regulations,” says David Duross, Quality Manager and ITAR Compliance Officer at NCAB Group USA.
ITAR, DFAR, EAR – what do they mean?
When dealing with circuit boards for the defense industry in the USA, there are regulations like ITAR, EAR and DFAR which you need to be compliant with. David Duross describes them and their purposes.
“ITAR (International Traffic in Arms Regulations) is one of two US export regulations intended to restrict and control defense and military related technologies and services listed on the US Munitions List (USML). ITAR and other export control regulations exist to protect national security and to prevent technology from falling into the wrong hands. Failure to adhere to the export controls can result in criminal prosecution resulting in fines and incarceration. ITAR-controlled PCBs are allowed to be manufactured outside the United States provided certain criteria is met and that legal authorization is granted by the US Department of State.”
“It is important to partner up with a supplier that understands and adheres to export control regulations”David Duross,
Quality Manager and ITAR Compliance Officer
NCAB Group USA
“We deal daily with ITAR and EAR questions. EAR (Export Administration Regulation) is the other US export regulation that applies to anything not restricted and controlled by the ITAR. Anything explicitly restricted and controlled under the EAR shall have an Export Control Classification number (ECCN) assigned to that item or service”, David continues.
“And then there is DFAR (Defense Federal Acquisition Regulation) which is also important to have knowledge about. It is a set of US government regulations that govern the way the Department of Defense (DOD) acquires goods and services from Prime Contractors. A prime contractor is responsible for complying with DFAR clauses specified in their contracts with the DOD. The prime contractor is responsible for passing DFARs down to their second-tier subcontractor. Failure to follow some DFARs that flow down through the supply chain can result in early termination of the contract”.
What is export?
As used in the context of export controls, the term “export” covers a broad range of activities that include the export of products, services or information. In general, an export occurs when there is any transfer to any non-U.S. person, either within or outside of the U.S., of controlled commodities, technology, or software, by physical, electronic, oral, or visual means, with the knowledge or intent that the items will be shipped, transferred, or transmitted outside of the USA. (source: DEC)
What to think about when doing business with other countries for example in Europe?
“In Europe there are regulations of NATO and/or EU and/or the actual country´s policy. The principle remains the same, which is following the rules, declaring the export, use, securing the data, selecting the right supplier”, explains Estelle Blocklet, Factory Manager Europe at NCAB Group.
“For example, countries like the UK, Singapore and Germany require information to allow the export of military goods. A license will then be delivered, we call that export license in this case. Export license for military goods give us the right to export the goods with a license number. This will be essential to declare the goods properly, following the country regulation. Export licenses are not always required on PCBs depending on the country. Some regulate the PCB A and not the PCBs.”
“We have to show due diligence and evaluate the risks”Estelle Blocklet, Factory Manager Europe
What do you need to do to get an export license?
“When working with export licenses, we need specific information on the PCBs to ensure we are working with the correct export regulation legally. As David said before, we are not allowed to ignore the law. We have to show due diligence and evaluate the risks”, says Estelle Blocklet. “In general, for all export control of military products the information needed are (it can variate from country to country):
- Product Name / Part No:
- Is the PCB designed for use in a military product or system?
- Is the PCB intended for “Dual use” – a commercially available product that has been “modified for military use”?
- Is the PCB a component intended for use in connection with development, production, handling, operation, maintenance, storage, identification, or dissemination of chemical, biological, or nuclear weapons or other nuclear explosive devices, or the development, production, maintenance, or storage of missiles capable of delivering such weapons.
- What will the PCB be incorporated into?
- What function or part will it be used for?
- Who and where will it be assembled?
- Who and where is the consignee?
This information will help to determine the ML classification and the right license to use. Some of the export licenses are restrictive on the list of goods or country to export to.
Is it both the PCB supplier and the factories that need to be compliant to the regulations?
“Yes, and this cannot be highlighted enough; a customer must inform us if it is defense, we must inform our supplier that it is defense, and our supplier must handle the order as defense. We are in the obligation to know the intended use of our products and be able to declare them when they are defense products and know if they are not,” says Estelle.
How can customers feel safe buying defense PCBs from NCAB?
NCAB Group USA and NCAB Group Elmatica (in Norway) both have long experience from handling those types of PCBs and questions. “We have a process for this, from sending the Gerber files via a secure file transfer program, to a system handling all data, and our Factory Management teams in Taiwan, US and Europe that support our factories to ensure the export control is well handled”, Estelle Blocklet explains. “Our Factory Management staff is trained on a regular basis regarding this. And we are also educating people within the whole NCAB Group so that we have qualified experts in each local office. This means that each office will be up to date with their own local regulations and restrictions.”
Currently, NCAB has three approved factories in the UK, one in Singapore, and one within the EU that is compliant to the defense regulations. For ITAR we have factories in the USA and Taiwan.
How do I know that my PCB order is covered by ITAR, EAR or DFAR?
“What regulations (ITAR, EAR and DFAR) are applicable depends on where the PCB is designed and in what type of application it will be used. There are some rules that applies to the different types of applications,” explains Jan Pedersen, Technical Director at NCAB Group
“The result of being noncompliant with any of the rules, standards and provisions can be quite serious”Jan Pedersen, Director of Technology
Are there any specific requirements when designing for defense?
Military Grade PCB require high reliability with long service times under extreme conditions. PCBs for military applications such as aviation, ground activities, defense, naval applications, and space weapons requires a wide range of materials, composites, and construction. The general rule for a PCB design is to meet IPC class 3 requirements, which means the design shall also meet IPC-2220 sectional standards for PCB design.
What are the standards to be aware of?
“MIL-PRF-31032 is a performance specification; in other words, it was established to test PCBs to certify that they meet the necessary requirements for military use”, says Jan Pedersen.
“This specification intends to allow the device manufacturer the freedom to enact best commercial practices while still delivering products that meet military performance needs. Certification to this standard is intended for manufacturers of the kinds of devices mentioned above that wish to be suppliers to the Department of Defense. To deliver, the factory needs to be certified to MIL-PRF-31032. To become certified, a company must submit a formal request to the Department of Defense for a certification audit.
“In general MIL-PRF-31032 requires IPC class 3 design and performance, but MIL–PRF–31032/3 replaces IPC-6011 series test Frequency and Performance Requirements. In addition, MIL-PRF-31032 is stringent on external visual requirements, but basically in line with NCAB PCB Specification”, Jan continues.
“The Allied Quality Assurance Publications (AQAP) are standards for quality assurance systems developed by NATO”, says Jan. “The aim of the AQAP agreement is to define standards for quality assurance of defense products. These standards are an integral part of contracts awarded in the military field involving NATO member countries. AQAP documents are therefore important to contractors and companies wanting to bid for such contracts. For a PCB supplier, compliance to AQAP 2110 – NATO Quality Assurance Requirements for Design, Development and Production-, is required”.
Noncompliance to the rules – what will happen?
“The result of being noncompliant with any of the rules, standards and provisions can be quite serious. It can mean the shipment will be stopped in export customs, the forwarder can decline to carry the goods, the goods can be stopped in import customs, and finally the customer can be forced to decline receipt”, says Jan Pedersen.
“If we break the technical rules of our customer, the defense contractor have all rights to reject the goods delivered. The worst a PCB supplier can do is to pretend ignorance. In the defense industry ignorance is not acceptable. We SHALL know what we do when we accept orders from a defense related company, or from an EMS when the end customer is known. This is exactly why NCAB is continuously monitoring standards, regulations and rules that is applicable to the defense industry. Being a reliable partner with sufficient knowledge to all these rules is a safety for our customers”, Jan Pedersen finishes off.