[time-nuts] US export regulations for TICs

Jim Lux jimlux at earthlink.net
Tue Jul 7 15:06:57 EDT 2015


On 7/7/15 6:28 AM, Attila Kinali wrote:
> Moin,
>
> As we need a need a proper TIC here to do our research, we are
> going to buy one from ebay form a seller in the US and let a friend
> who is in the US at the approriate time and can pick it up to bring
> it back in the plane.
>
> Now the big question is, are there any export regulations regarding
> such equipment and if yes, where do I find it? (my search didnt show
> up anything approriate). Yes I know it's a boat anchor and that takeing
> it in a plane is kind of iffy, but it's better than shipping it.
>

Ah, the complexities of Export Controls, with which I deal every other day.

I'll summarize a bit here, for the benefit of other list members who 
might contemplate this.  If it's straying too far off the list topics, 
let me know...

Ebay sellers in general don't know anything about export controls, other 
than some just don't sell to foreigners (which they think neatly solves 
that problem it doesn't).

In export control, there are US Persons and non-US persons.  The former 
are US Citizens and legal permanent residents (green card holders), who 
are NOT representatives of a foreign entity.  You can be a US citizen, 
but work for, say, Thales-Alenia Space Italia, and be a non-US person.

If you are transferring export controlled goods (or information!) to a 
non-US person, you *may* need an export license, depending on what the 
goods are.  Where the transfer takes place is immaterial (so if your 
friend going to do the pickup isn't a US person, the export would occur 
when he or she put their hands on the goods).

Now to whether you need a license.  There are two kinds of export 
controls in the US: US Munitions List (ITAR), run by the department of 
state, and Commerce Control Regulations (CCR) run by the Department of 
Commerce.

USML stuff almost always needs a license, a non-trivial process 
requiring, typically, an "end user certificate" describing who the 
ultimate recipient is (e.g. you can't say "I'm buying it for myself", 
when, really, you're transferring that 17-axis milling machine to a 
"designated country")

You can easily google the USML (the version at fas.org is a bit out of 
date): it's fairly straightforward, and MOST of the stuff will say 
"specially designed for military purposes", so a piece of test equipment 
that has multiple uses probably won't be controlled, unless it's 
designed to be bolted into a fighter or ship or carried by an infantry 
soldier.

There are some "no conceiveable dual use" things on the USML: GPS 
receivers that work at more than some high altitude or at Mach 5 are a 
nice example.

For USML/ITAR stuff ALL exports need a license.

Then, there's the EAR/Commerce rules.  For these, which are much broader 
and cover more commodities and things, there's a "which country is it 
going to" distinction.  Shipping fast CPUs to the UK, no problem; 
Shipping to North Korea, can't do it.


USML is here https://www.pmddtc.state.gov/regulations_laws/itar.html

I would suggest looking at Category 11 (Military Electronics)
for which there was a recent amendment:
https://www.pmddtc.state.gov/FR/2014/79FR37536.pdf


the Export Administration Regulations (EAR) are here
https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear

Chapter 3 might be of interest. It has rules on RF amplifiers, arbitrary 
waveform generator, signal analyzers, etc.  I've never looked for 
counters or TICs.



>
> Thanks in advance
> 				Attila Kinali
>



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