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Questions about ITAR/EAR regulations? |
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Is your cruise making a foreign port stop or working in foreign territorial waters?
If yes, please be aware that certain instrumentation may be subject to ITAR or EAR. It may seem odd, but ITAR (International Traffic in Arms Regulations) and EAR (Export Administrative Regulations), DO apply to some oceanographic instrumentation and its documentation/software. Some known examples are some inertial reference units, gyroscopes, accelerometers, night-vision goggles, and seismic streamers. Note that the regulated instrumentation may be within a larger instrument (e.g. gravimeter, ROV, AUVs).
The regulations and the instrumentation to which they apply can be found here:
• ITAR: 22CFR 120-130 ( https://www.pmddtc.state.gov/regulations_laws/itar.html )
• EAR: See the Regulations section of of the Bureau of Industry and Security (http://www.bis.doc.gov/ ).
Other sources of help are:
• Your institution’s Export Control Officer.
• The instrumentation’s manufacturer. Please note that the manufacturer may not disclose this upon purchase because they may have been unaware of any plans to take it into a foreign country.
Non-compliance with ITAR and EAR can come with heavy fines. It is up to the PI to acquire the necessary permits.
As of 2Feb15 – The UNOLS community is compiling a more detailed document explaining ITAR and EAR. This document should be out in the coming months. |
