• Certain optically switched coatings and laminates for spacecraft threat resistance

  • ultraclean, nickel-based alloys, powders, processes, and products for high-performance jet engine parts

  • initiators for ultrahigh energy materials

  • high-performance armor and penetrator materials


Current Methodology

The subpanel reviewed advanced materials controlled under various export commodity control numbers (ECCNs) and made the following observations concerning the methodology by which the materials are determined to warrant control. A specific analysis of several entries on the Commodity Control List is attached as Annex Al.

  • The ECCN entries are defined too broadly and the rationale for control is not clearly stated in either the Commerce Department's Commodity Control List or in the Defense Department's Militarily Critical Technologies List.

  • Although the Commerce Department's technical advisory committees (TACs) are sometimes consulted on the foreign availability of materials, they are not consulted in determining the critical nature of materials. Moreover, the TACs do not adequately interact with the State Department's technical working groups.

  • The list construction/management process does not take into account the dynamic nature of technology transfer from military to commercial applications, or vice versa. No attempt is made to assess the market opportunity or economic impact of restricting trade in the materials.

  • Some of the advanced materials on the Commodity Control List have no direct relation to a current DoD mission area (e.g., superconductor magnets, NASP technology).

  • Foreign countries often have superior capabilities in producing some of the controlled materials (e.g., Soviet Union in energetic materials, Japan in silicon chips).


This review was undertaken prior to the development of a core list of CoCom-controlled items that was begun in the latter half of 1990. Although the analysis of the subpanel remains valid, the categorization and control status of many materials will change when the core list exercise is completed.

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