BIS final rule removes EAR license requirements for certain spacecraft and related items exported to Australia, Canada, and the United Kingdom

Mechanism

The final rule amends Supplement No. 1 to EAR Part 774 to remove licence requirements for selected ECCN 9A515 spacecraft and related items when destined to Australia, Canada, or the United Kingdom. Items covered by the carve-out include:

• Remote-sensing spacecraft (sub-paragraphs within 9A515.a) that

meet thresholds for ground-sample-distance and revisit capability short of the most sensitive end-items.

• On-orbit servicing, assembly, and manufacturing (OSAM) systems —

including rendezvous & proximity-operations (RPO) vehicles, space tugs, and in-space logistics platforms — that are increasingly central to commercial space-services markets.

• Associated parts, components, and "specially designed" subsystems

for the above end-items.

For these items, exports and reexports to AU/CA/UK no longer require a BIS licence. The rule does not affect controls when the same items are destined to any country outside the AU/CA/UK trilateral group; the parallel IFR (FR Doc 2024-23958) handles broader allied liberalisation of 9A004.x and 9A515.x "specially designed" parts/components under NS2/RS2.

The legal basis for the trilateral carve-out is the National Technology and Industrial Base (NTIB) construct under 10 U.S.C. 4801, which Congress extended to include the United Kingdom in the FY2017 NDAA (originally a US/Canada-only mechanism, now US/CA/UK/AU post-AUKUS).

Downstream implications

• Material relief for the US small-satellite and commercial space

services industry exporting to UK primes (Surrey Satellite Technology, In-Space Missions, Astroscale UK), Australian primes (Gilmour Space, Fleet, HEO), and Canadian primes (MDA, Telesat, NorthStar Earth & Space).

• Removes a long-standing friction point for AUKUS Pillar 2 space

cooperation, where bilateral defence projects routinely required BIS licences for component-level transfers.

• Operationalises the trilateral NTIB partnership extension to the

UK (2017) in the space domain — previously most of the practical benefit had accrued in air/maritime defence cooperation.

• Part of a coordinated 2024-25 allied push to harmonise dual-use

export controls on advanced technologies (semiconductors, AI compute, biotech, and now space).

Open questions

• Whether subsequent BIS rulemakings post-2024 extended the AU/CA/UK

spacecraft carve-out to additional Five-Eyes partners (NZ) or AUKUS-aligned destinations (JP, KR).

• How DDTC's parallel USML Category XV rule (State Department side)

handles the same set of trilateral partners; that rule is a separate instrument and will be tracked independently.

• Whether the Commercial Space Activities (CSA) license-exception

proposal (FR Doc 2024-23975) was finalised in 2025 as a separate rule providing broader multilateral relief.