Does Magic Black fall under ITAR regulations?
Magic Black pigments do not REDUCE detection by infrared equipment – rather they INCREASE / ALLOW detection by infrared equipment. For that reason we can not find any prohibition of the use of Magic Black in the ITAR regulations.
Here are the only two areas of the regulations that we find infrared related materials that have any relevance to Magic Black.
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ITAR Regulations - 2013 edition
Page 482
Clothing to protect against or reduce detection by radar, infrared (IR) or other sensors at wavelengths greater than 900 nanometers, and the specially treated or formulated dyes, coatings, and fabrics used in its design, manufacture, and production.
Page 496
Materials, devices, and specially designed software for reduced observables such as radar reflectivity, ultraviolet/infrared signatures on acoustic signatures (i.e., stealth
technology), for applications usable for the systems in Item 1 or Item 2 (see § 121.1, Category XIII (e) and (k)), for example: (a) Structural material and coatings specially
designed for reduced radar reflectivity; (b) Coatings, including paints, specially designed for reduced or tailored reflectivity or emissivity in the microwave, infrared or ultraviolet spectra, except when specially used for thermal control of satellites.
Disclaimer: The fact that we can not find reference to materials that INCREASE / ALLOW infrared detection in the ITAR Regulations, does not in any way mean that someone in authority, who does not know the regulations, or understand the way that Magic Black works will not claim that Magic Black is regulated.