[time-nuts] US export regulations for TICs

[John Miles]

> 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.

It's been a couple of years since I had to look into this stuff myself, but from what I've seen, frequency/TI counters aren't covered by State Department ITAR/USML rules unless they're part of a dedicated weapons system.  For everything else, you need to search the Commerce Control List _carefully_ to be sure of the item's classification.  When in doubt consult an attorney who specializes in export law.  The cost of making a mistake can be out of all proportion to common sense, and relying on random advice found on the Internet (including mine) is a bad idea.  

That being said, you'll find a lot of hits on the CCL for terms like "analyzer," "oscilloscope," and "digitizer," but not for "counter."   As Jim suggests, commercial electronic equipment generally falls into CCL category 3.   The catchall classification for test equipment not otherwise listed is 3A992, which requires you to apply for an export license for items destined for Sudan.  (Of course, some other countries such as Cuba, North Korea, and Iran will require more paperwork regardless of the item in question.)

So as far as I'm aware, unless (a) the specific item is controlled as an ITAR munition, (b) you are shipping it to a questionable destination (or knowingly causing it to end up there),  or (c) or you are transferring it to someone on various official sh!t lists (http://export.gov/ecr/eg_main_023148.asp), you're OK.

-- john, KE5FX
Miles Design LLC