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How about ITAR resources? Is a bare PCB ITAR restricted?

1607 1 Feb 15.2020, 17:06:42

I am confused about how ITAR works.  Wondering if anybody has ITAR links or resources that can answer any of the following questions.
A bare PCB without any components populated on it is only a collection of wires and pads.  Without the schematic and the BOM included in the data package, there is no chance any external party could deduce what the bare PCB  is used for, or otherwise utilize it for nefarious purposes -- it remains a collection of wires, devoid of any function. Therefore, how could a bare PCB ever be classified as an ITAR-regulated item? Who makes this decision? And how does one find an expert in the matter to answer the intricacies of such inquiries?

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