Export Controls: Classification of data storage system with controlled software pre-installed

Question

How would you classify a data storage system that is not controlled under category 4, as it doesn’t meet the APP limit but is shipped loaded with software that is classified under 5D002

(This question was asked at one of our recent webinars on Export Controls. You can listen to this webinar on our recent webinars page at http://opentoexport.com/info/webinars/)

Answer

A data storage system is a piece of equipment and will be considered under Sub Category A of a Dual Use entry. If it has software loaded on to it that gives it a controlled encryption function, the data storage unit will be considered under entry 5A002. If the software is shipped separately it will be considered under entry 5D002.

Menu
Export Action Plan