Export controls and compliance policy
Aumictech LLC · Effective January 1, 2025 · U.S. Export Administration Regulations (EAR) — 15 CFR Parts 730–774
What this policy covers
Aumictech LLC complies with all applicable U.S. export control laws, including the Export Administration Regulations (EAR) administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS), and the sanctions programs administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). This policy applies to every international sale and shipment of used test and measurement equipment.
We are a U.S.-based company (SAM-registered, CAGE code 14B36) and operate exclusively within U.S. export control requirements. We do not knowingly export items in violation of U.S. law and will not process orders that would require us to do so.
EAR classification of common test equipment
The EAR assigns an Export Control Classification Number (ECCN) to controlled items on the Commerce Control List (CCL). Items not listed on the CCL are designated EAR99. Most commercial used test equipment falls into one of these categories:
| Instrument type | Typical EAR status | Notes |
|---|---|---|
| Optical spectrum analyzers | EAR99 | Commercial-grade OSAs from Yokogawa, Ando, Keysight, JDSU are generally EAR99. |
| OTDRs | EAR99 | All commercial OTDR platforms (EXFO, Viavi, Anritsu, Yokogawa) are EAR99. |
| Optical power meters & sources | EAR99 | Commercial optical test components are EAR99. |
| Fusion splicers | EAR99 | Fujikura, Sumitomo, Furukawa commercial splicers are EAR99. |
| Tunable laser sources | EAR99 | Commercial TLS platforms (Agilent 81600, Keysight N7776) are generally EAR99. |
| Signal generators (≤20 GHz) | EAR99 or ECCN 3A001 | Confirm per model. Most HP/Agilent 836xx benchtop units are EAR99. |
| Signal generators (>20 GHz) | May be ECCN 3A001 | Higher-frequency microwave generators require individual review. |
| Spectrum analyzers | EAR99 or ECCN 3A002 | Confirm per model. Most benchtop units to 26.5 GHz are EAR99. |
| VXI/PXI modules | Varies | Evaluated per module type. Contact us before ordering. |
EAR99 items require no export license for shipment to most non-embargoed destinations. This table reflects general classifications — the buyer is responsible for verifying the EAR status of any specific instrument for their end use and destination. ECCN documentation is available on request for any unit in our inventory.
Embargoed destinations and OFAC sanctions
Aumictech does not ship to embargoed or comprehensively sanctioned destinations, regardless of item classification. As of the effective date of this policy, these include:
- Cuba (OFAC comprehensive embargo)
- Iran (OFAC comprehensive sanctions)
- North Korea (OFAC comprehensive sanctions)
- Syria (OFAC comprehensive sanctions)
- Russia and Belarus (broad BIS/OFAC restrictions on most goods)
- Crimea region of Ukraine (OFAC sanctions)
- Donetsk and Luhansk regions of Ukraine (OFAC sanctions)
This list is subject to change as U.S. sanctions programs are updated. Buyers in countries not on this list but subject to partial restrictions should contact us before ordering. We will verify destination-specific requirements before processing the order.
Denied parties screening
Every international order is screened against the following lists before shipment is authorized:
- OFAC Specially Designated Nationals and Blocked Persons List (SDN)
- BIS Denied Persons List
- BIS Entity List
- BIS Unverified List
- State Department Debarred Parties List
If a match or potential match is identified, the order is held and the buyer is notified. We do not ship to listed parties. False or misleading end-user information provided to circumvent these checks may constitute a federal crime under U.S. export control law.
End-user statements and documentation
For instruments classified above EAR99, or for any shipment where due diligence requires additional documentation, we request a completed End-User Statement before processing the order. The statement identifies the ultimate end user, the intended end use, and confirms the item will not be re-exported to a prohibited destination without proper authorization.
Contact us at sales@aumictech.com before placing an international order if you need to confirm EAR classification, request an ECCN letter, or discuss end-user documentation requirements. We typically respond within one business day.
Frequently asked questions
Can Aumictech ship used test equipment internationally?
Yes. Most commercial optical and RF test equipment — OSAs, OTDRs, power meters, fusion splicers, benchtop signal generators under 20 GHz — is classified EAR99, which requires no export license for most destinations. We cannot ship to embargoed countries including Iran, North Korea, Cuba, Syria, Russia, and Belarus regardless of item classification.
What export classification does test equipment typically carry?
Most commercial benchtop test equipment is EAR99, the lowest restriction level, requiring no license for non-embargoed destinations. Some wideband signal generators and spectrum analyzers operating above 31.8 GHz may carry ECCN 3A001 or 3A002 classifications and require additional review. We evaluate each order individually and provide ECCN documentation on request.
Do you verify denied parties before shipping internationally?
Yes. Every international order is screened against the OFAC Specially Designated Nationals list, the BIS Denied Persons List, the BIS Entity List, and the BIS Unverified List before shipment. If a match or partial match is flagged, the order is held pending manual review. We do not ship to flagged parties.
Do you require an end-user statement for controlled items?
For items above EAR99 classification, or for any shipment to a destination that triggers additional due diligence under the EAR, we require a completed end-user statement before the order ships. We provide the statement template on request. International buyers should contact us before ordering to confirm classification and documentation requirements.
Are optical test instruments covered by ITAR?
Commercial-grade optical test instruments — optical spectrum analyzers, OTDRs, tunable laser sources, optical power meters — are generally controlled under the EAR (Commerce), not ITAR (State). ITAR applies to defense articles on the U.S. Munitions List. Military-specification or purpose-built defense instruments may be ITAR-controlled; we do not knowingly inventory ITAR-controlled items, but buyers are responsible for verifying end-use compliance.
Contact for export inquiries: sales@aumictech.com · +1 (484) 841-9341 · Aumictech LLC, 788 S 500 E, Pleasant Grove, UT 84062 · CAGE 14B36 · SAM-registered
External resources: BIS (bis.doc.gov) · OFAC (ofac.treasury.gov)