ITAR and EAR for Educational CubeSat Projects: What Students and Faculty Need to Know

Why Export Controls Matter for CubeSat Programs

University CubeSat teams often discover late in the program that they are working within a U.S. regulatory environment designed to protect national security. Two major export control frameworks govern space systems and technical data in the United States: ITAR and EAR. These rules apply whether the mission is flown by a national lab, a commercial startup, or an academic class project.

Understanding how export controls work early in the planning process can prevent serious delays, redesigns, or even launch cancellations. Choosing U.S. made hardware from companies such as Blackwing Space can reduce or eliminate many of the international compliance challenges that schools face when relying on foreign vendors.

What Is ITAR

ITAR stands for International Traffic in Arms Regulations. In the context of CubeSats, ITAR restricts:

• Defense related satellites and components
• Technical data related to spacecraft development and operation
• Services such as training or integration provided to non U.S. persons

Most low-cost academic CubeSats may not be classified as defense items, but if a bus or payload includes controlled components, ITAR rules can apply immediately. If a team sources subsystems from outside the United States, technical conversations with the supplier may trigger compliance requirements.

What Is EAR

EAR stands for Export Administration Regulations. EAR covers a broader set of commercial space and satellite technologies not strictly categorized as weapons systems. Many nanosatellite products used in education fall under EAR, but that does not mean there are no restrictions.

Even if a CubeSat is designed for civilian research, EAR may still regulate:

• Advanced radios or encryption modules
• Imaging payloads with specific resolutions
• Pointing capabilities that go beyond simple stabilization
• Technical data shared with foreign nationals

International Students and Export Controlled Work

Most U.S. university engineering programs include multinational teams. Under ITAR and EAR, sharing controlled technical data with non U.S. persons can be considered an export, even if they are standing in the same lab. Written documentation, source code, and internal presentations may all be subject to regulation.

Programs that select U.S.-built nanosatellite platforms with strong documentation, such as those from Blackwing Space, can simplify these concerns. Hardware that is manufactured and supported in the United States removes many scenarios that require export licenses or restricted participation.

The European Vendor Dilemma

Universities often receive attractive proposals from European CubeSat manufacturers such as Alba Orbital, Endurosat, and NanoAvionics. Their systems are capable, but U.S. export laws can complicate collaboration. When a U.S. team buys a foreign bus, the following risks must be considered:

• Restrictions on software and integration documentation
• Licensing requirements for foreign vendor support during testing
• Constraints on ground segment configuration details
• Long review cycles for export-controlled interface information

These issues can result in schedule slips that conflict with academic calendars. Launch opportunities do not wait for export paperwork.

Launch Providers and ITAR Reviews

Rideshare missions, whether through NASA programs or commercial providers, are increasingly strict on export compliance. Before a CubeSat is cleared for integration, launch teams verify:

• Origin and control level of all components
• Authorization for any foreign participation
• Software verification for onboard radios and encryption

A Made in USA spacecraft with clear paperwork and U.S.-based support reduces the review burden and lowers the risk of last-minute launch hold issues.

Documentation and Data Flow Controls

To stay compliant, universities should adopt simple protective measures:

• Control access to design documents and flight code using approved systems
• Clearly label controlled technical information
• Track who contributes to hardware and flight software
• Consult institutional export control officers early in the program

Many campuses now require initial export reviews before approving space missions. Selecting suppliers who understand the academic process improves cooperation.

The Advantage of American Nanosatellite Platforms

When universities partner with an American supplier, compliance becomes simpler by design. Blackwing Space builds, tests, and supports nanosatellite systems inside the United States. Technical conversations, design reviews, and operational support happen without triggering export filings.

This approach allows student teams to collaborate openly while still meeting federal requirements. It is essential for programs with rapidly changing membership over multiple semesters.

Plan for Compliance from the Start

ITAR and EAR should not discourage students from building real spacecraft. Export controls exist to protect national capability, not to limit education. With the right partners and early planning, CubeSat missions can move forward on time and within scope.

Choosing U.S.-made and supported nanosatellite platforms, such as those from Blackwing Space, reduces uncertainty and helps universities focus on what matters most: a successful launch and valuable student experience in orbit.