UC Comment Letters

This comment letter responds to the Department of State Directorate of Defense Trade Controls (DDTC)'s proposed amendments to the International Traffic in Arms Regulations (ITAR) originally issued on July 29, 2024. UC supports DDTC’s proposed ITAR revisions as a helpful effort to clarify defense-services controls, distinguish controlled from non-controlled activities, and protect national security while preserving professional and academic exchanges. UC endorses AUECO and COGR requests for further clarification on exclusions for repair or maintenance of EAR-controlled commodities/software, routine academic activities, medical and translation services, and definitions related to intelligence activities, so low-risk academic and research activities are not unnecessarily affected.