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

Absolutely correct.