RAPTAC / Regulations & Procedures Roundup

The Commerce Department’s Bureau of Industry and Security Regulations and Procedures Technical Advisory Committee held a marathon open session Tuesday, with a particular emphasis on the microelectronics supply chain.

Sharron Cook, of the BIS Regulatory Policy Division began with an update on the October 7th Advanced Computing and Semiconductor Manufacturing Equipment Rule . Comments were due January 31st, with the final rule pending interagency review. No date is available for publication of the final rule, though an updated FAQ is in review and will be available “shortly.”  

“Always look at your red flags, audit your supply chains to the extent possible, to identify in the US origin inputs in the production of the items, and obtain confirmation from suppliers regarding the origin of parts and components,” said Ms. Cook. “And as always, keep good records to back up your analysis of the transactions.”

Next up, a team from the Strategic Radiation Hardened Electronics Council discussed collaborative efforts across agencies and industry to ensure survivable electronics, terrestrial and in space.

The SHREC Initiative, begun in 2018, is “important as we're modernizing all of our nuclear weapons programs, space programs and missile defense program. Most of the technology that we have in our legacy systems is based on 150 nanometer node technology which is early 90s technology, so state-of-the-art technology is something that we're interested in doing now.

“Radiation hardened microelectronics for Department of Defense is a niche within a niche within a niche, so we have very small demand. Really only the US government DoD has those requirements, so it's really hard to get state-of-the-art technologies based on our demand. It's hard for the companies to make money when they only have so many wafers.”

Researchers are discovering what can be referred to as "radiation hardened by serendipity, where properties of circuits li the very low nanometer sizes (14 and below)  are increasingly being discovered through testing as having very attractive talents, or even hardened properties. This is coming off the standard commercial manufacturing processes"

Other speakers included Evan Broderick Acting Executive Director for the Information and Communications Technology and Services program at BIS (See Below), an update on Enforcement from Kevin Kurland, Deputy Assistant Secretary for Export Enforcement, Charles Wall, BIS Senior Policy Advisor on the US-EU Trade and Technology Council and Matthew Borman , Deputy Assistant Secretary of Commerce for Export Administration.