Export control for space hardware: classify, screen, document

Caelex is software for compliance workflows and legal research. This article is not legal advice and does not replace licensed counsel.

A thruster, a star tracker, a ground modem, or a firmware image can be dual-use or military-listed depending on origin, specs, and destination. Email threads are not an export-control system.

The job that actually exists

1. Classify the item (EU Dual-Use, national military list, USML/CCL when US-origin rules apply). 2. Screen parties and destinations. 3. Decide licence, exception, or no-licence-required — that decision belongs to the export officer and, where needed, counsel. 4. Document the file so a later audit is not a reconstruction from Slack.

Passage is built for that loop: classify, screen, and document shipments with the export officer in control.

What Passage does not do

• It does not grant a BAFA, ITAR, or EAR licence

• It does not replace the empowered official

• It does not “clear” a shipment because a model said the ECCN looks right

• It does not make US re-export analysis disappear for EU operators using US-origin parts

If a tool claims to issue export clearance, treat that claim as a red flag.

Space-specific traps

• US content in a European bus. ITAR/EAR can follow the part.

• Cloud and software. Deemed exports and remote access are easy to miss.

• Launch campaign logistics. Brokers, freight forwarders, and range vendors are parties too.

• In-orbit servicing and debris removal. The hardware may be dual-use even when the mission story is sustainability.

Keep the officer in the loop. Use software to make the loop inspectable.

Caelex is currently in pilot operation.