I'm performing a design exercise for the design of attitude control system using reaction wheels as control actuators. During the analysis, I noticed few interesting options from suppliers in the US. I make an assumption in the design study that it is a European based space mission. Now I'm wondering does ITAR regulations restrict US-based companies to sell to European based satellite missions for reaction wheels? Or is it risky to choose hardware from companies that fall under ITAR regulations? Any links/literature with regards to this will be much appreciated!

Thanks in advance!


2 Answers 2


Reaction wheels are a borderline technology, one that in certain situations might require an export license. What I suspect is the case is that they will be able to sell you the reaction wheels, but will be unable to give you all of the technical data that might make your job easier. Still, I would contact the supplier, ultimately they will be responsible for getting the export license to send their product overseas, and thus they should be familiar with exactly what restrictions they have.

  • $\begingroup$ Thanks for the answer! I have a follow-up question: Do the same criteria apply to Canadian companies? Because I'm guessing Canada is much more relaxed with regards to the export of Space qualified hardware right? If so, I would assume the procurement from Canadian suppliers will be much easier and hassle-free compared to US suppliers? $\endgroup$
    – srikarad
    Commented Dec 11, 2018 at 13:21
  • $\begingroup$ I have no idea about Canada, but I do know ITAR applies to the US, and several countries have similar laws. I think Canada is freer then the US in such regard, but again, I would contact the potential supplier. $\endgroup$
    – PearsonArtPhoto
    Commented Dec 11, 2018 at 13:51

Really old thread, but adding a more thorough answer as it may help others with similar questions

You can check if a particular space technology is ITAR controlled by accessing the United States Munition List (USML) which is Part 121 of Title 22 of the Code of Federal Regulations. In particular go look under Category XV paragraph (e) "Spacecraft parts, components, etc" There you will notice that while certain complete attitude control systems (e)(10) and control moment gyros (e)(13) are listed, reaction wheels are NOT listed. That means that they are NOT controlled by Department of State ITAR.

However... like all other items, from spacecraft to pencils, they are controlled by the Department of Commerce EAR regulations. For that you can check the Commerce Control List which is Supplement 1 to Part 774 of Title 15 of the CFR. In particular you want to look at Category 7 (Navigation and Avionics) and Category 9 (Aerospace and Propulsion). Components such as RW would be controlled under paragraph 9A515 "Spacecraft" and related commodities. In particular their Export Control Classification Number (ECCN) is 9A915.x (Parts and components "specially designed" for spacecraft)

What does this mean to you? It means that a US company WOULD most likely require an export license to send a reaction wheel from the US to Europe, but that export license is no harder to obtain than export licenses for thousands of other non-space related commodities. As long as your study is not based in Iran, China, North Korea, Russia, Cuba, etc, you are fine calling out a US reaction wheel in your design.

Some side notes:

  • To some countries it may even be possible to export the reaction wheels under a license exemption -- but that requires more research than I have time for. The reaction wheel vendor would be able to tell you right away. Exemptions are covered in Part 740
  • Even if your component was ITAR controlled, you can still export it to most European countries. It just needs to go through a different licensing regime. ITAR does NOT mean you cannot export.
  • Canada and Europe also have their own export regulations. It isn't necessarily easier to export something from Canada than from the US.

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