The ITAR Trap: How U.S. Export Control Law Is Ceding the Commercial Launch Market to China and Europe

Key Takeaways

• After satellites were moved to ITAR in 1999, US commercial satellite market share fell from 83% to 50%
• The 2024 EAR Interim Final Rule represents the most significant export control reform in a decade
• China launched 68 rockets carrying 270 satellites in 2024 while building an ITAR-free supply chain

An Origin Story Nobody Wanted

In February 1996, a Chinese Long March 3B rocket carrying the Intelsat 708 satellite, built by Space Systems/Loral, failed catastrophically shortly after launch and plunged into a nearby village. In the aftermath, engineers from Loral and Hughes Electronics participated in investigations into the launch failure, sharing technical findings with Chinese rocket engineers. The U.S. government subsequently concluded that some of that information could have assisted China’s ballistic missile program. Loral paid a $20 million fine in 2002. Hughes paid $32 million in 2003. Boeing, which had acquired Hughes’s satellite business in 2000, faced related investigations over its Sea Launch joint venture.

Congress reacted with sweeping legislation. In 1998, the FY 1999 National Defense Authorization Act transferred jurisdiction over commercial satellite exports from the Department of Commerce’s Export Administration Regulations, where they had been managed as dual-use items, back to the State Department under the International Traffic in Arms Regulations. ITAR had been designed for military weapons systems. It was written during the Cold War, in 1976, to implement unilateral arms export controls against Soviet-aligned countries. Applying it wholesale to commercial communications satellites reflected congressional anger about a genuine security lapse, but it also imposed on a civilian industry a regulatory framework designed for armaments.

The consequences arrived quickly and compounded over years. By 2008, America’s worldwide market share in satellite technology had declined from 83% to approximately 50%, as The Economist noted at the time, a decline that coincided directly with the transition to ITAR oversight. Academic analysis published in the Southern Methodist University Journal of Air Law and Commerce estimated that U.S. satellite manufacturers lost up to $6 billion attributable to ITAR between 1999 and the mid-2000s. For companies that had previously competed freely for international contracts, ITAR compliance costs, licensing delays, and the blanket embargo on any U.S.-origin content reaching China or other proscribed destinations transformed the competitive calculus of every procurement decision worldwide.

What ITAR Actually Does

ITAR governs the export of defense articles and defense services identified on the U.S. Munitions List. The State Department’s Directorate of Defense Trade Controls administers and enforces it. Any American company that manufactures, exports, or brokers goods or services on the Munitions List must register with DDTC and obtain licenses for exports, re-exports, or transfers to foreign nationals, including in some cases foreign employees working within the United States.

The compliance machinery this creates is substantial. A medium-sized satellite component manufacturer must maintain an ITAR compliance program, conduct regular training for employees, screen all foreign national employees and visitors, obtain individual export licenses for shipments to most countries, track technology wherever it travels in the supply chain, and ensure that any foreign party receiving U.S.-origin items does not re-export them to proscribed destinations without additional U.S. authorization. For a company with a small international sales team and thin margins, the direct cost of this infrastructure, including legal counsel, DDTC registration fees, compliance officers, and the time cost of license applications that can take weeks or months to process, can represent a significant fraction of international revenue.

The licensing process itself introduces commercial uncertainty that compounds the direct cost. A foreign customer evaluating U.S. and non-U.S. options for a satellite component faces not only the price of the component but the risk that the U.S. export license won’t be approved, will be approved with conditions, or will take long enough that it affects the program schedule. European alternatives that require no license approval eliminate that risk entirely. When a procurement officer at a satellite operator in the Middle East or Southeast Asia is comparing options, ITAR-free status is a commercial attribute with a real dollar value, the value of avoided compliance risk and schedule uncertainty.

The definition of what counts as ITAR-controlled has been expansive and, from the perspective of the space industry, often unpredictable. European satellite prime contractor Thales Alenia Space discovered that ITAR’s reach had been extended to include essentially anything that goes into space, “no matter how inconsequential,” as one export counsel summarized it to Space News. A single U.S.-manufactured component in an otherwise European satellite could make the entire satellite subject to ITAR licensing requirements, potentially disqualifying it from launch on Chinese or other proscribed rockets and requiring license approval before any foreign nationals, including allied-country engineers, could work on the relevant technical documentation.

The term “ITAR-free” became a commercially significant marketing designation for European satellite manufacturers. Oxford Space Systems’ chief executive told Space News it was among the first questions he heard from prospective customers: “Are we dependent on any U.S. materials? Do we have ITAR-free status?” That question, posed to a British startup developing deployable satellite antennas, illustrates how thoroughly ITAR had restructured global procurement preferences. Customers who could find ITAR-free alternatives would choose them not because the U.S. technology was inferior but because the compliance burden and the risk of collateral restrictions made it commercially unattractive.

The embargo on China specifically has remained unchanged through every subsequent ITAR reform. No U.S.-origin content, regardless of how insignificant or commercially available, can go to China or the roughly 18 to 19 proscribed countries. This absolute prohibition has given Chinese satellite and launch vehicle manufacturers a structural incentive to eliminate all American-origin components from their supply chains, accelerating the development of domestic alternatives that might never have materialized under a less restrictive export regime.

The 1999-2014 Period and Its Legacy

The fifteen years between the satellite transfer to ITAR in 1999 and the first meaningful reform in 2014 represent the period in which the most lasting competitive damage accumulated. European companies invested heavily in ITAR-free component development, subsidized by the European Space Agency and by individual national space agencies that recognized technology autonomy as a strategic priority. Thales Alenia Space, Airbus Defence and Space, and other European prime contractors built up capabilities in areas they had previously sourced from American suppliers, from high-efficiency solar cells to advanced infrared sensors.

The scale of this investment was substantial. ESA member states explicitly framed technology autonomy as a strategic industrial policy goal, funding the development of European alternatives to U.S. components in semiconductor devices, attitude control systems, and propulsion hardware across its member state national space programs. These programs were not purely commercially motivated; they were at least partly defensive responses to the recognition that dependency on ITAR-controlled American components created a vulnerability in European space programs that governments considered unacceptable from a sovereignty standpoint.

Arianespace, the European launch consortium, benefited from ITAR’s exclusion of U.S.-component satellites from Chinese rockets. Satellites with any American content could not legally fly on Long March vehicles, directing that business toward Ariane. When ITAR restrictions made a particular satellite program difficult for an American prime contractor to export cleanly, European alternatives were waiting. The combination of reliable Ariane launch services and growing European satellite manufacturing capability positioned Europe to capture significant commercial satellite contracts that would previously have gone to American suppliers.

Over the same period, Ariane 5, which made its maiden flight in 1997 and became the commercial heavy-lift market workhorse through the 2010s, was deliberately marketed and technically configured to accommodate non-U.S. satellites without triggering ITAR concerns. That positioning was not accidental; it was a direct response to the market opportunity created by American export controls. A satellite operator anywhere in the world, wanting to avoid ITAR complications on an international commercial program, had a natural incentive to use an ITAR-free European satellite on an ITAR-unconstrained Ariane rocket. The entire supply chain could then be managed without any engagement with U.S. export licensing, a practical advantage with real commercial value independent of any technical comparison between competing options.

The Global South and the Third-Country Problem

The ITAR debate in Washington is often framed in terms of the transatlantic relationship, allied-country collaboration, and the China embargo. That framing misses a large portion of the competitive dynamic. The fastest-growing markets for satellite communications, broadband connectivity, and remote sensing services are in Africa, Southeast Asia, Latin America, and the Middle East, regions that are neither members of the Wassenaar Arrangement, nor embargoed under ITAR, but that also don’t receive the streamlined treatment that allied Wassenaar members now enjoy.

For a satellite operator in Nigeria, Brazil, Indonesia, or Saudi Arabia evaluating connectivity infrastructure, the choice between an American-component system and a Chinese system is not formally constrained by ITAR. American exports to those countries require licenses, but licenses are generally available for commercial items. The problem is that obtaining those licenses takes time, introduces schedule uncertainty, and requires the foreign customer to engage with U.S. regulatory processes that have no equivalent when dealing with Chinese suppliers. Chinese satellite and launch providers operating entirely within their own ITAR-free supply chains offer a procurement experience that is commercially simpler, even when the underlying technology is comparable.

Belt and Road Initiative financing adds another dimension. China has used preferential loans, infrastructure packages, and technology transfer agreements to embed Chinese satellite systems into national telecommunications infrastructure across dozens of developing countries. As part of these arrangements, the local government receives not just the satellite or ground system but technical training, maintenance support agreements, and sometimes accompanying ground segment infrastructure. The financing terms are often more favorable than what Western commercial markets offer because they’re backed by Chinese state banks with strategic objectives rather than commercial return requirements.

ITAR doesn’t directly constrain Western operators from competing in these markets. But the compliance infrastructure required to export American-component systems to countries with complex ownership structures, potential state-enterprise involvement, or partnerships with proscribed-country entities creates a due diligence burden that has no equivalent in the Chinese competitive model. American companies doing business in markets where Chinese state enterprises are potential partners, customers, or financiers face exposure to ITAR’s deemed export rules for foreign nationals, re-export controls, and the requirement to ensure that U.S.-origin items don’t reach proscribed destinations through third parties. Navigating that exposure costs money and sometimes kills deals.

The Scientific Research Problem

ITAR’s impact on commercial competition is the most commonly discussed consequence of the export control regime. Its impact on scientific research, less commercially visible but potentially more consequential over the long run, has been documented by the National Academies and others, and has not been adequately addressed by either the 2014 or 2024-2025 reforms.

Space science research often involves international collaboration by design. Climate modeling, Earth observation, solar physics, and exoplanet research all benefit from combining data sources and instrumentation distributed globally. When a U.S. university research program involves a foreign graduate student working on technology that has any satellite application, the question of whether that student is a “foreign national” with access to ITAR-controlled technical data requires a compliance analysis. If the student is from a non-allied country, or if the research touches controlled technologies, a Technical Assistance Agreement or an export license may be required before the student can participate fully in the research.

The resulting friction discourages international students from choosing U.S. universities for space-related graduate study, discourages foreign institutions from initiating collaborative research with U.S. counterparts, and increases the administrative burden on American researchers to the point where some academic departments have elected to avoid U.S. government-funded space research rather than build the compliance infrastructure required to manage ITAR obligations. That self-selection effect, where the most internationally collaborative and productive research programs avoid controlled space technology specifically to preserve their collaborative freedom, is a subtle but real cost that the export control system imposes on American scientific leadership.

Congress authorized a shift in approach in 2013, and the reform took effect in November 2014 when commercial communications satellites were moved off the ITAR Munitions List and transferred to the Commerce Department’s Commerce Control List under the Export Administration Regulations. For satellites exported to the approximately 36 nations covered by the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies, licensing requirements were substantially reduced.

The reform was significant. It acknowledged that the across-the-board ITAR classification of commercial communications satellites had been a policy error with measurable commercial consequences. But it also preserved the China embargo without modification. No U.S.-origin satellite component could be sent to China before 2014 and still can’t in 2026. Launch vehicle technology remained under ITAR regardless of the satellite’s classification. And for the more than 150 nations that were neither Wassenaar members nor embargoed but fell into an intermediate category, licensing requirements remained real if somewhat less onerous than before.

The reform also came a decade after the worst competitive damage had already been done. European companies that had invested in ITAR-free component development didn’t dismantle those supply chains when American components became somewhat easier to export. The competitive capability Europe built during the ITAR years was not returned to American manufacturers when the rules eased; it remained in Europe and continued to grow.

The 2024-2025 Reforms and the EAR Interim Final Rule

The most significant overhaul of space-related export controls since 2014 came with the EAR Interim Final Rule in late 2024, building on a series of changes that reflected both industry lobbying and a growing recognition within the U.S. government that regulatory friction was costing American competitiveness in strategically important commercial markets.

Under the new framework, license exceptions were expanded for exports of certain space items to the 40 Wassenaar Arrangement countries. A new ECCN 9A515.x classification was created for commercial communications satellites, non-sensitive ground station technology, and lower-tier propulsion systems that no longer require individual export licenses for allied-country destinations. License Exception CSA, proposed in 2025, was designed to allow U.S. companies to work more easily with allied-country partners on space programs without triggering licensing requirements for routine technical exchanges.

President Trump’s Executive Order 14268 of April 9, 2025, directed the Departments of State and Defense to review the U.S. Munitions List to focus its protections on technologies where American security interests were concretely at stake, explicitly acknowledging that over-classification was undermining defense trade with U.S. allies. The August 2025 DDTC final rule implementing portions of that review made further adjustments to USML categories, removing some items to the CCL and creating new license exemptions for allied collaboration.

The China embargo has not changed. If anything, the competitive and security logic for maintaining it has strengthened in the context of the broader technology decoupling between the U.S. and China across semiconductors, advanced manufacturing equipment, and now space hardware. The 2025 rules emphasize facilitating allied collaboration while maintaining strict controls toward China and the other proscribed countries, a framework that reflects the current geopolitical alignment more accurately than the 1999 structure did, but that still leaves a significant gap between the ally-friendly provisions and the commercial reality of a global market in which non-aligned countries can choose between American and Chinese technology without the same compliance burdens.

China’s ITAR-Free Advantage

The deepest irony of the ITAR story is that the export control regime designed to keep American space technology out of Chinese hands has instead provided Chinese space manufacturers with a decades-long incentive to develop indigenous alternatives to every significant U.S.-origin component. By making American content radioactive for any satellite program that needed to fly on a Chinese rocket or be sold to a Chinese operator, ITAR accelerated the development of a domestic Chinese space supply chain that now competes with American companies in third-country markets.

China launched 68 rockets carrying 270 satellites in 2024, according to War on the Rocks analysis, and was on track to exceed that pace in 2025. Goldman Sachs analysis cited by Aviation Week in November 2025 estimated that China could provide around 75% of planned launches for announced LEO satellite constellations expected between 2025 and 2031, based on announced government satellite plans totaling 70,000 satellites globally. Even if that figure overstates the realistic Chinese launch share, the trend line is clear. CASC, China’s state aerospace corporation, and a growing ecosystem of commercial rocket companies including LandSpace and others are building methane-fueled reusable launch vehicles that directly target the market position SpaceX occupies in the West.

Shanghai Spacecom, which is developing the 15,000-satellite Qianfan constellation, had launched 90 satellites in under a calendar year by mid-2025 and was targeting 648 more by the end of the year. The company has agreements to provide internet service in Brazil, Thailand, Malaysia, Kazakhstan, and China, and is in discussions with more than two dozen other nations. Those markets are not subject to ITAR. A government in Southeast Asia or West Africa evaluating satellite connectivity providers faces no legal obstacle to choosing a Chinese system, no compliance burden from doing so, and often an attractive commercial offer backed by Belt and Road Initiative financing. The ITAR constraint that makes American technology difficult to integrate into a procurement program involving any Chinese counterparty becomes a reason, all else being equal, to choose the Chinese provider and avoid the problem entirely.

The European Calculation

Europe’s response to ITAR has evolved from reactive compliance to strategic technology autonomy planning. The European Space Agency’s IRIS² constellation program, a multi-orbit government broadband constellation representing a major European infrastructure investment, was designed from the outset to use European components and avoid ITAR entanglement, partly because European policymakers determined that a sovereign communications infrastructure dependent on American-licensed components was insufficiently sovereign.

Arianespace and its parent ArianeGroup have built their market positioning around the ability to offer European-developed launch services for European-built satellites in a way that creates no exposure to American export control law. The Ariane 6 rocket, which made its maiden flight in July 2024, is being positioned as the carrier of record for European institutional and commercial satellite programs that require ITAR-free end-to-end supply chains.

Germany’s OHB, a satellite prime contractor, has explicitly marketed its products as offering ITAR-free alternatives to American-component systems. The French national space agency CNES has invested in developing domestic capabilities in satellite components specifically identified as strategically important for avoiding ITAR dependency. These investments represent real costs in duplicating capabilities that already exist in the United States, costs imposed directly by the structure of American export control law.

What Comes Next

The 2024-2025 reform package represents a genuine shift toward a more commercially coherent export control framework for space, one that tries to facilitate collaboration with allies while maintaining strict controls toward adversaries. Whether it is sufficient to reverse the competitive ground already ceded is uncertain. The European ITAR-free supply chains are not going to be dismantled because licenses to allied countries are now easier to obtain. The Chinese domestic space component industry is not going to shrink because American competitors are somewhat more accessible in allied markets.

The more consequential question is whether the current framework is adequately calibrated for the competitive environment of 2026. SpaceX now accounts for roughly 80% of U.S. launches and a dominant share of global commercial launches, which means the practical ITAR burden falls disproportionately on smaller American companies trying to compete internationally. A medium-sized U.S. satellite component manufacturer competing for a contract in a non-allied developing country faces compliance costs that the Space Foundation estimated, in a 2007 white paper that remains relevant, were proportionally nearly eight times higher as a percentage of foreign sales for small companies compared to large primes. That asymmetry has not been eliminated by the 2024-2025 reforms.

One dimension of the problem that the 2024-2025 reforms partially address but do not resolve is the treatment of allied-country collaboration in research and development programs. ITAR licensing is required when foreign researchers, including those from allied countries, participate in U.S.-based research programs on controlled technologies. This requirement, as the National Research Council noted in a 2007 report that remains relevant, creates friction in exactly the international scientific collaborations that produce the next generation of technologies. Foreign researchers begin to view U.S. collaborative research programs as less attractive not because of the content but because of the compliance overhead. Over time this reduces the flow of international talent and ideas into American space programs, while it flows freely into European and increasingly into Chinese programs that impose no equivalent burden on international collaborators.

The structural problem underlying all of this is that ITAR was built on a concept of American technological primacy, the premise that U.S. space components were sufficiently superior to anything available elsewhere that restricting their export gave competitors no alternative but to either obtain American technology with U.S. conditions attached or fall behind. That premise was largely accurate in 1999. In 2026, it is no longer true for many categories of commercial space hardware. China’s domestic component capabilities have matured significantly. European ITAR-free alternatives exist across a wide range of satellite subsystems. When the United States restricts exports of items that competitors can now supply at comparable quality and lower compliance cost, it doesn’t protect American technology; it subsidizes the development of the foreign alternatives.

The deeper argument for the current ITAR framework, made by those who resist further reform, is that the China embargo is not about commercial competitiveness but about military technology transfer. They point out that commercial satellite technology and military satellite technology share a significant portion of their component base, that a solar cell array efficient enough for commercial broadband is also efficient enough for an ISR satellite, and that relaxing controls toward China on ostensibly commercial items would eventually leak into military applications. That argument has force. But it sits uncomfortably alongside the evidence that China’s domestic alternatives, developed precisely because U.S. components were unavailable, are now capable enough to support both commercial and military programs with or without American content. The strategic question, which ITAR policy has never resolved, is whether the embargo is preventing Chinese military capability development or merely inconveniencing it while ceding the commercial market.

Summary

ITAR’s application to commercial satellites starting in 1999 produced measurable harm to U.S. market share in satellite manufacturing and contributed to the development of competing European and Chinese supply chains that no longer depend on American components. The 2014 reform moved commercial communications satellites to the less restrictive EAR, and the 2024-2025 rules have continued to reduce the licensing burden for allied-country transactions. The China embargo remains absolute and is unlikely to change given the current geopolitical climate.

What remains unresolved is whether the current framework adequately accounts for the competitive reality that American technological primacy in many commercial space component categories has eroded over the 25 years since the original satellite ITAR transfer, and that maintaining strict export controls on items available elsewhere in ITAR-free form produces less security benefit and more commercial cost than the original legislative logic assumed. A satellite component that an American company can now export to Germany without a license but can’t export to Brazil without one, and can’t incorporate into any program touching China at all, is a component whose global addressable market is systematically constrained relative to the identical or equivalent product made by a European or Chinese competitor operating under no such restrictions.

The policy debate about whether ITAR’s costs are worth its benefits has a fundamental and persistent asymmetry that has never been satisfactorily resolved by any administration that has confronted it. The costs are visible, documented in lost contracts, declining market share statistics, and the compliance overheads that industry groups have been quantifying for decades. The benefits, consisting primarily of technologies not acquired by adversaries, are by definition invisible and counterfactual. That asymmetry makes the debate perpetually difficult to resolve on evidence alone. What the 25-year history of satellite ITAR does establish clearly is that export controls on commercially available technology do not prevent adversaries from obtaining equivalent capabilities; they primarily shift which national industry develops and profits from those capabilities. China in 2026 has domestic alternatives to every major U.S. satellite component category that ITAR blocked in 1999, and those alternatives are being deployed in the same developing-country markets where American companies had historically competed and won. Those alternatives were developed faster, spread further into global markets, and have now largely eliminated the technical gap that ITAR was originally designed to protect, because ITAR itself provided a sustained commercial incentive for their creation over a quarter century of regulatory pressure.

Appendix: Top 10 Questions Answered in This Article

What caused commercial satellites to be placed under ITAR in 1999?

In 1998, Congress passed the FY 1999 National Defense Authorization Act transferring commercial satellite jurisdiction from the Commerce Department’s Export Administration Regulations to the State Department’s International Traffic in Arms Regulations. The trigger was the investigation into Hughes Electronics and Loral Space Communications for sharing technical information with Chinese rocket engineers during failure analyses of Long March launches carrying U.S.-built satellites in the 1990s. Although the primary violations concerned launch vehicle technology, not satellite technology, Congress responded by placing all commercial satellites under ITAR.

How much market share did U.S. satellite manufacturers lose due to ITAR?

America’s worldwide market share in commercial satellite technology declined from approximately 83% to around 50% between 1999 and 2008, according to analysis published by The Economist and academic sources. Academic research estimated that U.S. satellite manufacturers lost up to $6 billion attributable to ITAR following the 1999 transfer. Not all of this decline is directly attributable to ITAR, but the timing coincides closely with the regulatory shift.

What is an “ITAR-free” satellite and why does it matter commercially?

An ITAR-free satellite contains no U.S.-origin components subject to International Traffic in Arms Regulations, meaning it can be exported, sold, integrated with foreign spacecraft, and launched on any rocket, including Chinese vehicles, without requiring U.S. government export licenses. European manufacturers including Thales Alenia Space and OHB developed and market ITAR-free products specifically because international customers routinely asked whether their systems were free of U.S.-origin content that could trigger compliance obligations.

What did the 2014 satellite export control reform accomplish?

The 2014 reform, effective November 10, 2014, moved commercial communications satellites off the ITAR U.S. Munitions List and onto the Commerce Department’s Commerce Control List. Exports to approximately 36 Wassenaar Arrangement member countries no longer required individual State Department licenses under most circumstances. The China embargo was not changed, and launch vehicle technology remained subject to ITAR regardless of the satellite’s reclassification.

What is the EAR Interim Final Rule of 2024 and what did it change?

The 2024 EAR Interim Final Rule expanded license exceptions for space items exported to the 40 Wassenaar countries, created new ECCN classifications for commercial satellites and lower-tier propulsion systems, and streamlined the compliance burden for allied-country transactions. A companion License Exception CSA was proposed in 2025 to facilitate routine technical exchanges with allied-country space partners. The China embargo was preserved unchanged.

What is China’s current position in the commercial launch market?

China launched 68 rockets carrying 270 satellites in 2024 and was accelerating in 2025. Goldman Sachs analysis estimated that China could potentially provide around 75% of planned launches for announced LEO constellation programs between 2025 and 2031. State-owned CASC’s Long March rockets and a growing commercial sector including LandSpace are developing methane-fueled reusable vehicles targeting the same market position that SpaceX occupies in Western markets.

How does ITAR affect smaller U.S. space companies disproportionately?

The Space Foundation estimated in a 2007 analysis that ITAR compliance costs, as a percentage of foreign sales, were nearly eight times higher for small companies than for large prime contractors. Smaller companies have less internal compliance infrastructure, fewer resources to manage licensing delays, and narrower margins that make the absolute cost of ITAR compliance more damaging relative to revenue. Some smaller companies have reportedly exited international markets or the space industry entirely because of ITAR’s sustained impact on profitability.

Why haven’t the 2014 and 2024 reforms restored U.S. market share?

The European ITAR-free component supply chains built during the 1999-2014 period represent genuine invested capital and developed engineering capability that did not disappear when American components became somewhat easier to export. Companies that built ITAR-free alternatives to American satellite subsystems created products that compete on their own merits, not solely as ITAR-avoidance strategies. Additionally, the China embargo means that for any program involving Chinese counterparties, American components remain excluded regardless of reforms to allied-country licensing.

What has China done with the ITAR-free competitive advantage?

China’s domestic satellite component manufacturing sector, driven partly by the commercial incentive to eliminate ITAR-controlled U.S. content from supply chains serving Chinese operators and allied markets, has developed indigenous capabilities in solar cells, propulsion systems, imaging sensors, and communications hardware that would previously have been sourced from U.S. or European suppliers. Shanghai Spacecom’s Qianfan constellation, targeting markets in Brazil, Thailand, Malaysia, Kazakhstan, and more than two dozen other countries, competes directly for connectivity markets that American operators cannot easily serve under the current ITAR framework.

What is Europe’s IRIS² constellation and why was ITAR relevant to its design?

IRIS² is a European Union multi-orbit broadband constellation program designed to provide European governments and institutions with a sovereign satellite communications infrastructure. It was designed from the outset to use European components and avoid U.S.-origin content that would create ITAR licensing obligations, giving European institutions the ability to use the system without exposure to American export control law. The program reflects a deliberate European policy choice to invest in technology autonomy rather than continued dependence on ITAR-encumbered American systems.