Export Compliance

Spacecraft propulsion hardware and technical data are regulated under the Wassenaar Arrangement, EU dual-use regulations, and applicable national law. ISPTech products are designed with these controls in mind. Our engineering team provides export documentation support for qualified customers.

EU 2021/821
Dual-Use Regulation
AWG/AWV
German Foreign Trade Law
Wassenaar
Arrangement
BAFA
Export Authority
Regulatory Context

Applicable Regulations

Wassenaar Arrangement

The Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies governs the transfer of propulsion technologies. Spacecraft propulsion systems, particularly those incorporating energetic propellants or providing significant ΔV capability, may be listed under Category 9 (Aerospace and Propulsion). ISPTech products are designed with awareness of Wassenaar Control List applicability. Formal classification determinations are required for each export transaction.

EU Dual-Use Regulation 2021/821

EU Council Regulation 2021/821 controls the export of dual-use items from EU member states. As a German company, ISPTech is subject to this regulation and to the German Außenwirtschaftsgesetz (AWG) and Außenwirtschaftsverordnung (AWV). Export authorisation applications to BAFA (Bundesamt für Wirtschaft und Ausfuhrkontrolle) may be required depending on the destination country and the specific technical parameters of the propulsion system being exported.

ITAR and EAR Awareness

United States export regulations — the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) — may apply to propulsion technologies that incorporate US-origin content or technical data. ISPTech maintains awareness of US re-export control requirements and advises customers on potential ITAR/EAR implications for propulsion system deliveries. This page does not constitute export control legal advice; customers should consult qualified export counsel for specific transactions.

Hazardous Propellant Regulations

Hydrazine (N₂H₄), monomethyl hydrazine (MMH), and nitrogen tetroxide (NTO) are regulated as hazardous chemicals under EU REACH Regulation 1907/2006, CLP Regulation 1272/2008, and the ADR/IATA regulations for transport. ISPTech provides Safety Data Sheets (SDS) and transport documentation for all propellant-wetted hardware deliveries. Customer facility authorisation requirements for hazardous propellant handling must be confirmed in advance.

Customer Support

Export Documentation Support

01

ECCN Determination Support

ISPTech can prepare technical description documentation to support Export Control Classification Number (ECCN) determination under EAR, and equivalent EU dual-use list classification. Note: formal classification decisions rest with the exporting entity and applicable authorities.

02

End-Use Documentation

ISPTech requires end-use and end-user documentation for all deliveries involving propulsion hardware or detailed technical data. Standard end-use certificate and non-re-export declaration forms are provided as part of the procurement package.

03

Technology Transfer Agreements

For space agency and institutional programmes requiring technology transfer or detailed qualification data sharing, ISPTech engineering team can support the preparation of Technical Assistance Agreements (TAAs) or equivalent instruments under applicable national law.

04

Compliance Records

ISPTech maintains export transaction records in compliance with German AWV record-keeping requirements. Export compliance documentation is available to qualified government auditors on request. Records are retained for the period required under applicable law.

This page provides general information about the regulatory context for spacecraft propulsion systems. It does not constitute export control legal advice and does not represent a determination that any specific ISPTech product is or is not subject to export control. Customers are advised to consult qualified export control counsel for their specific transactions and jurisdictions. ISPTech bears no liability for export control decisions made based solely on this page.

Export Compliance Enquiries

For export classification support, end-use documentation requirements, or to discuss compliance requirements for your programme, contact ISPTech directly.