Brilliant analogies aside, the Rule considers products to be on the USML list if any part or component in the commercial dual use item is on the USML. 

While tight export restrictions can be a good thing when it comes to protecting US technology from smarmy evildoers, industry, particularly the military industrial complex, is up in arms:  ”globalization” efforts and sales of dual use equipment to China are frozen since, as we all know, USML parts or their related technology can’t be sent there. It is also more costly, or even impossible to outsource production or to even export ITAR-tainted products for sale to other countries. Not to mention all that infected stuff out there was previously exported in more carefree days.

Thus, the industry argues, it will lose out against foreign competitors who aren’t impeded by Cold War era ITAR restrictions. So industry is still pushing for clarification of the see-through rule but the State Department won’t give it up just yet. A Big Chill was sent though the aeronautics industry a few years back when Boeing was fined $15 million because a USML classified QRS-11 navigation chip was included in a commercial engine exported for sale to