I never thought I would need to add export regulations to this collection but with the changes proposed, I have amateur rockets that will be on the "Munitions List".
The State Department published a NPRM on 23 October 2024 proposing a number of changes including one in particular that effects hobby rocketry. While amateur rockets and motors had largely been excluded by footnote, they want to make it a bit more official by including definitions for amateur rocket and amateur rocket motor. These mostly follow the NFPA codes with one really big problem.
Amateur rockets are limited to 40,960 N-s total impulse and no more than five pounds of propellant. The impulse limit follows NFPA but the weight limit does not. In fact the weight limit is a far stricter limit of much less than 1/4 of the impulse limit. This is a significant change as while the current footnotes limit the weight of rocket motors, they don't limit the capacity of amateur rockets.
And just because you have never used a motor that big do not think you are safe. If it can hold a motor with over five pounds, it isn't an amateur rocket. Thus the full weight of the ITAR regulations come into play. That would be Subchapter M of Title 22. There is way too much in there for me to want to read. But the top level summary is that export of such things without proper approval can get you into big trouble. Big trouble being a fine up to one million dollars, up to twenty years in prison, or both.
You don't have to ship it out of country to trigger the export limits. Transferring the item or its technical data to a foreign national is a problem. See definition of export at 120.50
Which is making me think again about my rockets with 75mm motor mounts. The Aerotech M1297 exceeds this limit.
This is still an NPRM so it might change before the final rule. I checked and found only 42 comments submimtted. Then the docket was opened for an additional 30 days and received over 2,000 more. They are public but the interface to read them is too useless for me to look at more than a few. My poor and not random sample shows they are mostly about this amatuer rocket exemption.
The footnote as it exists now:
Note 3 to paragraph (a): This paragraph does not control model and high power rockets (as defined in National Fire Protection Association Code 1122) and kits thereof made of paper, wood, fiberglass, or plastic containing no substantial metal parts and designed to be flown with hobby rocket motors that are certified for consumer use. Such rockets must not contain active controls (e.g., RF, GPS).
Note that paragraph (a) generally describes serious things. Like long range missiles with a payload. Or mines, bombs, torpedoes, etc.
The new definition:
Amateur rocket means an unmanned rocket that: (1) Is made of paper, wood, fiberglass, or plastic, and does not contain any substantial metal parts; (2) Does not carry a payload designed to be flammable, explosive, or harmful to humans or property; (3) Is propelled by one or more motors having a combined total impulse of 40,960 Newton-seconds or less; (4) Has a capacity for no more than five (5) pounds of propellant; (5) Has no active controls; and (6) Cannot reach an altitude greater than 150 km above Earth’s surface.
Several years ago I was poking around in my collection of electronic parts and happened onto a bag that I purchased at the Sandia Labs Salvage yard in the 70's. $1.50 for the three pound bag. I noticed something in it that looked familiar. But only because I had seen it on 60 Minutes.(Details of the operation here.) In that story someone ran afoul of ITAR by trying to circumvent the controls by trans-shipping through a third country. It looks like this.
A dual use item that besides its mundane uses is handy for triggering implosion style nuclear weapons.
I was thinking that I needed to include it in a rocket design named "Export Controlled". Now it seems I may already have rockets that are export controlled.
Federal agencies are required to publish an agenda of regulatory actions twice a year. They haven't been doing a good job of that recently with the most recent version being the "Spring 2025" edition. Published 4 September.
In that version, The State Department expected an Interim Final Rule In August 2025. Nothing yet.
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