[time-nuts] export controls and reverse engineering

[Jim Lux]

"Do you believe there may be a problem for those who are 
reverse-engineering, and posting on the open net, items which may be 
covered under these regulations?

If you do, you may want to consider contacting them off-list and letting 
them know your concern.

Peter

"


Man, export controls are a complex, confusing, and not at all tidy and 
rule-driven so that mere engineers can figure out what is covered and 
what isn't.  It is left up to diplomats and folks at departments of 
Commerce and State (in the US, anyway) to figure out using whatever 
means they have at their disposal.  (When I started getting into the 
whole export control and negotiating licenses thing at work, the first 
thing they told me was that as an engineer, I'd find it horribly 
frustrating, because it doesn't necessarily make sense)


In general, I would think that reverse engineering something bought 
surplus would NOT be subject to export controls.  Obviously, if a 
spacecraft or spare nuclear weapon fell in your backyard and you 
commenced reversing it, that would probably raise some issues.

A lot revolves around whether the thing you are fooling with is 
considered a "defense article" or "munition", for which you need to go 
to the lists.  Spaceflight qualified atomic clocks are definitely on 
that list, but these are not them.  FEI does, however, produce things 
that are export controlled, so they may take the easy way and treat 
everything as controlled unless there's a reason not to: hence the 
boiler plate on invoices from parts distributors when you order BNC 
jacks warning you about export controls.


The US Munitions List (USML) does have a whole section on atomic 
frequency standards, and you want to take a look at the performances 
listed there and see if you're in the ballpark (I suspect not).  They 
would be interested in particularly small, low power, or rugged sources.


Be aware that ITAR is only half of export control.  Department of 
Commerce also has the EAR.  There you want to look at "dual-use" 
technologies.