Infiray Jerry 31 - Does ITAR apply to Gen 2+ ?

Hudson456 Joined Nov 2021 Posts 136 EE 0% (0) NY, USA	Posted: 1/26/2024 12:59:31 PM EDT I just learned of the existence of these Chinese duals with NNVT-4 (1400-1600 FOM) tubes. Are these tubes allowed under ITAR to be taken out of the country legally? I was thinking international travel might be a good application for these.

sheepdog697 Joined Sep 2017 Posts 1055 EE 100% (32) IN, USA	Posted: 1/26/2024 3:38:38 PM EDT [#1] Since its not "United States" originated technology (I'm sure they used our stuff to make theirs at some point) I would think...no? Interested to see what others have to say.

chosos

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Posted: 1/26/2024 4:05:05 PM EDT

[Last Edit: chosos] [#2]

We have export specs for tubes - i think its like 1200 or 1400 FOM - it is pretty low. My understanding is that when most of these devices come in, they cannot go back out without proper paperwork. I have never exported anything, so a vendor would likely be able to better speak to this. It also depends on where it is going - are they a friendly country, or are you trying to ship it back to China/Russia?

From a different forum:
"I recently also asked the supplier of my NVD (ACTinBlack - Luxembourg) if I would have problems taking it to and back out of the US, with its European-made Gen3 tube, to entertain the possibility of bringing it with me whilst on a conference next year.

The answer was an unhesistant "Yes, as it would fall under ITAR immediately upon crossing the US border."

So no chance of a non-US citizen bringing non-US made Gen2/3 NVDs into the US either, at least not with a chance of being able to take it out again."

Light Reading:
https://www.federalregister.gov/documents/2020/01/23/2020-00574/international-traffic-in-arms-regulations-us-munitions-list-categories-i-ii-and-iii

erwos Joined Dec 2009 Posts 2584 EE 100% (27) USA	Posted: 1/26/2024 4:33:49 PM EDT [#3] Quote History Originally Posted By sheepdog697: Since its not "United States" originated technology (I'm sure they used our stuff to make theirs at some point) I would think...no? View Quote Incorrect. Once it's here, it's covered by ITAR. Whether it's actually ITAR controlled is a different story.

TNVC TNVC - ARFCOM MAIN SITE SPONSOR Joined Jan 2002 Posts 41745 EE 100% (76) USA	Posted: 1/26/2024 4:43:39 PM EDT [#4] Quote History Originally Posted By chosos: We have export specs for tubes - i think its like 1200 or 1400 FOM - it is pretty low. My understanding is that when most of these devices come in, they cannot go back out without proper paperwork. View Quote Absolutely correct.
	Tactical Night Vision Corporation - TNVC, INC. http://www.tnvc.com [email protected] (909) 796-7000 Dedicated to the men and women in uniform who fight the good fight.

GroundhogOZ

Joined Jun 2020
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AUS

Posted: 1/28/2024 4:53:23 AM EDT

[Last Edit: GroundhogOZ] [#5]

OP if outside the US (and not intending to come into the US and leave again) why would you buy those tubes, just buy decent Harder or Photonis tubes - they are way better than those PRC Ekran grade tubes.

The better Photonis tubes 4G+ have the best autogating across all manufacturers, best shock rating, best IA, best halo, best "highlight" lp/mm, generally best EBI <<< 1 and best spectral range. Some will gripe about gain but its typically 50k.

Alternatively, give an OPSIN a go - no issues with travel at all.

Deltastone

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Posted: 1/28/2024 5:18:06 AM EDT

[Last Edit: Deltastone] [#6]

Quote History

Originally Posted By sheepdog697:
Since its not "United States" originated technology (I'm sure they used our stuff to make theirs at some point) I would think...no?

Interested to see what others have to say.

View Quote

ITAR for NVG is, to use an simple analogy, a Guilty Until Proven Innocent affair as fair as classification. It's basically best to consider it ITAR unless you know for a fact it has a lesser export control. There are some Gen 2 that would not be covered under ITAR, but you have to prove with the spec sheets they are bad enough to not be covered under ITAR as part of your export process, otherwise it's basically going to just be considered ITAR controlled.

But even then, it's still going to be export controlled just in a different, more lenient way. Still requires some understanding of the paperwork.

In short, it's real easy for anything to come in and real hard for it to go back out.