Microcontroller capable of ADC or DAC operations – which export control list?

Question

If microcontroller is capable of ADC or DAC operations should we compare the microcontroller against 3A001.a.5 “Analogue-to-Digital Converter (ADC) and Digital-to-Analogue Converter (DAC) integrated circuits”

(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

When considering goods against the Control List, you compare the item you have against the most relevant entry . In your example, you would compare the microcontroller against the list. It is not an analogue to digital converter integrated circuit and so it would be wrong to try to classify it against entry 3A001.a.5. Microcontrollers will often also contain accelerometers and gyros but you would not need to compare these against Category 7. You will need to check the microprocessor against entries where it is listed such as 3A001.a.2. The only exception to this is if the microprocessor contains encryption in which case you will also need to consider Category 5 Part 2 in addition to any other relevant category. There is also a control in entry 4A003.e which could apply if the microprocessor is built on to a board.

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