Re: Export Classification Assistance
Rocco, Rick wrote:
> I am an export compliance coordinator with HP. I am currently
> reviewing applications for exportability. Could you please provide
> the Export Control Classification Number (ECCN) and the Commerce
> Classification and Tracking System number (CCATS), if applicable, or
> the local equivalent, such as the "Export Control Rating" for
> exports from the EU under the terms of the EU dual-use lists (EC
> Regulation 428/2009 as amended), for the following products? If
> these products are classified as "5D002", could you advise whether
> they qualify for any license exceptions?
Our best answers are easily found from http://lists.debian.org/search.html
"First of all, I am not a laywer. So the following is not legal
advice, but only what i know.
I'm not aware of any ECCN that would cover an operating system as a
whole. However, parts of Debian may be covered under ECCN
5D002. However, those parts fall under the TSU licence exception, so
no licence is required for that component. I'm not sure of any other
applicable ECCN. Also note that the ECCN of a GNU/Linux distribution
can vary depending on what components of it are exported. (Your GSM
gateway presumably does not use every component of Debian
GNU/Linux).
Your safest bet would be to submit a classification request for the
entire system to BIS, as described in the answer to question 3 at
http://www.bis.doc.gov/Licensing/Do_I_NeedAnECCN.html "
Above text from Joe Smith in Message-id: <fb1p2d$njg$1@sea.gmane.org>
I thought debian is probably
Operating system software, development tools & compilers - 4D003.a
but I do not know whether anyone has exported it under that code.
Also, like Joe, I'm not a legal advisor, or any sort of official.
Please let us know if you get an official classification on that,
so we can add it to our web site.
Thanks,
--
MJR/slef
My Opinion Only: see http://people.debian.org/~mjr/
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