[time-nuts] US export regulations for TICs

[Bob Camp]

Hi

….. and that’s just the quick brief summary.

If you are buying the product from the original manufacturer, the simple
thing to do is to ask them if a certificate is required. That’s not definitive,
but it’s probably a good start. If they are making controlled items and are
not aware of it, that’s pretty unusual. 

Bob

> On Jul 7, 2015, at 3:06 PM, Jim Lux <jimlux at earthlink.net> wrote:
> 
> 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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