Thermal Camera Export Restrictions
Exportable and Embargoed Countries for Thermal Infrared Imaging Camera Sales
Exporting thermal cameras, infrared cameras, or infrared sensors to certain countries may be restricted by the United States Government’s thermal camera export restrictions and many fall under International Traffic in Arms Regulations (ITAR). All ITAR items are designated by the U.S. Department of State. Some cameras fall under a specific ECCN Codes or an Export Control Classification Number (ECCN). ECCN items are governed by the U.S. Department of Commerce “Bureau of Industry and Security.”
Most countries can purchase uncooled microbolometer based, 9 Hz thermal imaging cameras without restriction. This depends on the sensor size and pixel pitch. For example, an ICI 9640 S, 9 Hz 640 x 480 microbolometer camera with 17 um pixel pitch can be exported to most non embargoed countries. Thermal cameras with pixel pitch smaller than 17 um may be an issue as determined by the U.S. Department of State. Thermal imaging cameras with 640 x 512 pixel resolution and up can be purchased by any country except U.S. Embargoed countries such as North Korea, Iran, Venezuela, etc as long as the frame rate is slowed to 9 Hz. Also, most ICI cameras have Commodity Jurisdiction (CJ) Code for them, but others do not.
Many countries can receive thermal imaging cameras with restrictions and proper documentation. As the law varies from country to country, please, consult with ICI or your export expert to learn the exact restrictions and documents needed for export, if any.
Violations of ITAR are extremely serious and can result in fines, debarment, and criminal sanctions. Please direct any questions or concerns regarding the export status of ICI’s thermal imaging cameras to Gary Strahan, ICI’s Manager of International Traffic, at 1-409-861-0788.
IMPORTANT: Please do not make any purchase or shipping decision relating to any infrared product based solely on the information provided on this site. This chart is provided as a general summary of various requirements set forth in multiple regulations and statutes. It is not intended to provide any definitive answer as to the exportability of any particular product nor is it intended to be relied upon for any purchase or shipping decision. In addition, it is not intended to be a complete listing of all provisions, regulations or statutes relating to the sale of Infrared Cameras Inc’s (ICI) infrared products. ICI will make all decisions, including approvals of orders, shipping instructions and license requirements based upon an independent review of the facts and circumstances of each order. Therefore, this information should not be relied upon in any way other than for the purpose that it is intended which is to provide potential customers with a general overview of the regulatory framework relating to ICI’s infrared products. You are strongly encouraged to seek your own counsel for advice regarding the export, re-export, retransfer and import of any infrared product before making a purchase decision.
Export Licenses, Restrictions, and Policies
Please note that ICI does not apply for export licenses on behalf of customers – we apply for licenses only for orders that ICI is exporting. ICI also doesn’t export on behalf of US companies, i.e., take an order from a US company and deliver it to a foreign party.
Any US company that purchases a camera from that intends to export it is obligated to apply for the license themselves. ICI provides information on how to register to do that on an ‘Export Fact Sheet’ as a convenience for its customers.
Obtaining an Export License
In order to obtain an export license, the ultimate consignee or end user of the infrared product must furnish an end-use statement on company letterhead to ICI. The end user must also complete a BIS-711, Statement by Ultimate Consignee and Purchaser. Quoted delivery times are based upon receipt of the validated export license from the Dept. of Commerce, which takes 8-10 weeks on average, depending on the end-use application, completeness of the end-use statement, and verification of the end-user.
ITAR Regulations Details
The International Traffic in Arms Regulations (ITAR restrictions) details the regulations governing the export of defense related materials and technologies. The U.S. Munitions List (USML) categorizes goods and technologies governed by the ITAR.
Country Group A:5
Argentina, Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, the Netherlands, New Zealand, Norway, Poland, Portugal, Republic of Korea, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, and the United Kingdom.
Central African Republic, Cote d’Ivoire, Cuba, Democratic Republic of the Congo, Eritrea, Iraq, Iran, Lebanon, Liberia, Libya, North Korea, Somalia, Sudan and Syria. [§746.1 and §126.1] Additional end-users as prohibited by General Prohibitions set forth in §736, incorporating by reference §744 and nuclear, missile, chemical and biological or maritime nuclear end-uses.
See country policies and embargoes for more information.
The countries shown below are Wassenaar Countries. All “Wassenaar Agreement” countries are currently able to purchase microbolometer based thermal imaging cameras up to 384 x 288 pixel resolution and 17 um pixel pitch without restrictions.
Argentina, Australia, Austria, Belgium, Bulgaria, Canada, Croatioa, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, India, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Mexico, Netherlands, New Zealand, Norway, Poland, Portugal, South Korea, Romania, Russia, Slovakia, Slovenia, South Africa, Spain, Sweden, Switzerland, Turkey, Ukraine, United Kingdom, United States of America
License Exception Strategic Trade Authorization (STA) §740.20 may be available in place of an export license.
Export license required for all items for Military End-Use or Military End-User to all destinations with the exception of Canada.
For further information regarding the applicable laws, regulations, and policies please contact:
US Department of Commerce, Bureau of Industry and Security (BIS)
Telephone: (202) 482-4811
US Department of State, Bureau of Political-Military Affairs, Directorate of Defense Trade Control (DDTC)
Telephone: (202) 663-1282
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