US Digital wants to do export control on us

I just received a weird letter from U.S. Digital, the maker of the encoders supplied in previous years KOP. We bought some encoder cables from them last year.

They want us to certify that we are in compliance with all applicable laws regarding exporting of controlled components to embargoed or restricted countries. We apparently have to have a company name and a legal representative to sign this form.

Did anyone else get such a strange letter?

What’s this country coming to when high school kids have access to supplies that could cause World War 3?

It’s probably a regulatory hoop they have to jump through. Don’t worry about it and fill it out.

You could probably try calling them and asking about it, explain your situation, they probably have better guidance than you can get off of people guessing on CD.

Why? Isn’t this US Digital’s problem?

Until you need the product again and they wont send it to you, sure.

Texas Instruments has a similar form when I purchase parts from them. I usually use our school’s name, “Warp7 Robotics” or just “student” as the company name. It’s always gone through just fine.

Yes, Team 1501 got the same letter. It was because we purchased directly from them.

As funny as this sounds to you and me, the government wouldn’t see it that way! Export control is serious business, and failure to comply (yes, even for a silly cable) would be vaguely akin to hearing that it *usually *doesn’t rain oobleck in Saskatchewan-- and then deciding to build your summer home there.

If I was in the same situation, I would put us down as “Lightning Robotics” and get a signature from our sponsoring teacher at the high school.

The US Export Administration Regulations prohibit export of certain enabling technologies to embargoed countries. The country list varies depending on what technologies we’re talking about, and applies to anything made in the US from little baby diodes to full up integrated products. Their concern is the end use of the product and country of destination. In this case, you can pretty safely state the end use (an education robot) and country of destination (your team’s country).

Disclaimer: I Am Not A Lawyer, nor an Export Control Officer. I have had the (mis?)fortune to deal with the EAR and other export control issues during purchasing, marketing, and sales of various products I’ve designed. This stuff all sounds far more scary than the actual burden on the hobbyist.

If you’re the type who just **LOVES **to read stuffy documents on a .gov site, see below. Encoders (and all sorts of other electronics) are subject to the EAR under Category 3 of the Commerce Control List:

https://www.bis.doc.gov/index.php/forms-documents/doc_download/990-ccl3

I guess that silly person would be me :). So this doesn’t have any real practical applications, but I did a quick look through that document and the only mention of encoders that I could find was for absolute encoders with an accuracy of +/- 1 arcsecond, which equates to >14 bits of resolution. Looking at US Digital’s website, it appears that they don’t even make any encoders that meet that standard.

Keep in mind that if you (the team) bring your robot to another country that is under export control from the US then your team just became an exporter. Using it in the US =no problem. Embargoed countries shift with political winds. China, for example, might be undrr export control for some items and I know there is an off season event. Encryption technology is another thing typically under export control (I forget how many bit encryption is ok and how much is restricted). I’m not an expert, but I do work with export control and ITAR.