Special Commercial Satellite Licensing Regime (COMSAT)

In order to expedite export licensing to U.S. allies of commercial satellites, satellite technologies, their components and systems to NATO allies and non-NATO allies, the U.S. Government (USG) has established a special processing regime that allows exporters to use high volume or 'bulk' licenses for satellite components and related technical data. Under the regime, the exporters will not need to provide in advance the details of purchase orders or contracts or retransfer and end use certificates. Instead, exporters will need to submit the mandatory export documentation within 15 days following shipment from the U.S. More importantly, the regime will permit export and re-export of U.S. origin components and technical data without prior USG authorization for an approved list of allied aerospace programs and firms. 

The list of pre-approved firms can be found at http://pmddtc.state.gov/comsat_frgn_prsn.htm .

The list of pre-approved programs can be found at http://pmddtc.state.gov/docs/COMSAT_Chart_Approved_Programs.xls .

To qualify for the COMSAT licensing regime an exporter must be:

• registered with the Office of Defense Trade Controls (ODTC), and
• be exporting specifically designed and modified components, systems, parts, accessories, attachments, associated equipment, and associated technical data for commercial communications satellites.  

Note that, under the regime, the above listed articles must not include detailed design, development, manufacturing or production data, and must not involve the overseas manufacture of significant military equipment (SME).   

To have the regime procedures apply, the exporter may submit DSP-5, DSP-73, and/or DSP-61 license applications, which, if approved, will be valid for four years and will cover multiple permanent and temporary exports and temporary imports of commercial satellite equipment and data.     

April 15, 2008