Legal and Regulatory

UK Government introduces new export controls on metal 3D printers

The UK Government has introduced new export controls on ‘emerging technologies,’ including metal 3D printers, semiconductors, quantum computers, and cryogenic cooling systems.   

The new controls restrict shipments of military goods and dual-use technologies which can be used for civilian and military applications.

In relation to additive manufacturing, the restrictions impact metal 3D printers that employ lasers, electron beams or electric arcs. The transfer of software for the use, development or production of these technologies is also prohibited under the new rules. 

A license will now be required to export the specified technologies outside the UK. 

Implemented by the UK Export Control Joint Unit (ECJU), the regulations came into force on 1 April 2024 under The Export Control (Amendment) Regulations 2024 (ECO 2024). They impact Schedule 3 and Annex 1 of the Export Control Order 2008.    

These changes reflect a global trend of tightening export controls to protect and retain advanced technologies for economic and national security purposes. They are also representative of growing efforts to create a strong domestic 3D printing supply chain on British soil amid global insecurities and threats to shipping.      

The amendments seek to align the UK’s export restrictions with other ‘like-minded countries’ such as the US and those in the EU. 

France, Spain and the Netherlands have all recently implemented unilateral export controls on advanced technologies. These have extended the scope of export restrictions beyond dual-use goods specified within the EU Dual-Use regulation.    

Wire Arc Additive Manufacturing. Photo via Ramlab.
The export of Wire Arc Additive Manufacturing technology will be restricted under the new rules due to its use of electric arcs. Photo via Ramlab.

New export restrictions for metal 3D printers  

The amendments specify that the export of 3D printers ‘designed to produce metal or metal alloy components’ will be restricted if they use inert gasses or a vacuum of less than 100 Pa for atmospheric control. 

The affected 3D printers also feature in-process monitoring equipment, such as internal cameras, pyrometers, radiometers and spectrometers, as well as a closed-loop control system. The latter adjusts 3D printing parameters based on real-time feedback from the monitoring tools.      

The restriction also limits the export of semiconductor technology, including integrated circuits and equipment used to manufacture semiconductors, including dry etching and micro imaging. 

Quantum computers are also impacted by the new export rules, along with cryogenic cooling systems, cryogenic wafer probing equipment and advanced materials. The affected materials include certain fluorides, hydrides, or chlorides of silicon or germanium, as well as specific silicon, silicon oxides, germanium or germanium oxides.      

In addition to the explicit control of hardware, the amendments also prohibit the export or  ‘transfer by electronic means’ of software used in the ‘development’ or ‘production’ of these technologies.

This is the first time the UK government has implemented protections for these technologies in recognition of their importance to national security. 

The expansion of export controls was outlined in last year’s National Semiconductor Strategy policy paper. Here, the government committed to strengthening the protection of UK semiconductor assets to prevent ‘hostile actors’ from building technology capabilities that could harm national security.       

Additive manufacturing export controls  

Additive manufacturing technology has previously been subject to tightened export controls in the US. In 2018, the Bureau of Industry and Security extended export controls on a plethora of ‘emerging technologies,’ including additive manufacturing, AI, robotics, and machine learning.

At the time, those within the 3D printing industry expressed concern that these increased restrictions would negatively impact technological development. Aerospace manufacturers Airbus and Boeing both detailed concerns, arguing that additive manufacturing technology itself does not represent national security concerns. 

However, several companies have been found in breach of regulations. 

In 2022, Rapid Cut, Quicksilver Manufacturing and US Prototype were accused of illegally sharing sensitive technical drawings and blueprints with Chinese manufacturers.  

The companies are believed to have asked Chinese manufacturers to produce 3D printed satellite, rocket and other defense-related prototypes. In this process, the firms allegedly shared sensitive technical drawings and blueprints without authorization. Each subsequently had their export licenses suspended for 180 days by the US Department of Commerce

Similarly, 3D printer manufacturer 3D Systems was ordered to pay up to $27 million to three US Government departments following allegations that it violated U.S. Export Control rules. The company is said to have unlawfully exported unauthorized material overseas, including files related to the repair, operation, production, and development of U.S. spacecraft.       

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Featured image shows Wire Arc Additive Manufacturing. Photo via Ramlab.