Strict compliance with U.S. laws and regulations that control exports and govern international business activities is a top priority for Globecomm Systems Inc. The management of Globecomm directs every officer, director, agent, and employee of Globecomm to understand the basic elements of such laws and to comply with them at all times.
The Export of Globecomm’s Products is Subject to Regulations Established by Both the US Department of Commerce and the US Department of State.
The regulations set forth by the Department of Commerce are called the Export Administration Regulations (EAR). For general information on the EAR, refer to www.bis.doc.gov. Those set forth by the Department of State are called the International Traffic in Arms Regulations (ITAR). For general information on the ITAR, refer to www.pmddtc.state.gov. If a product is considered a Defense Article pursuant to the US Munitions List (USML), then ITAR applies; if not, the EAR applies.
EAR Export Controls
Most of Globecomm’s products are export controlled under the EAR under classifications 3A992, 5A001, 5A002, 5A991, 5D991, 5A992, 5D992, or EAR99. This is important to know if you are actively engaged in any exporting activity. Many Globecomm products can be exported as “NLR” (no license required) or under license exception ENC. However, in some circumstances, an export license from the US Department of Commerce may be required. If you are unsure of the product classification, please contact Globecomm.
ITAR Export Controls
A select few Globecomm products are export controlled under the ITAR under Category XI of the USML. For these products, you generally must have an export license from the U.S. Department of State, Directorate of Defense Trade Controls, prior to exporting either the product or any technology or technical data related to the product. Some important considerations are:
If you incorporate a Globecomm product that is ITAR-controlled into your system, your system becomes ITAR-controlled and you are considered a “manufacturer” of a “Defense Article.”
In order to export an ITAR-controlled item, you must either use a license exemption or apply for an export license from the US Department of State. In either case, you must first be registered with the US State Department and have an ITAR export compliance program in place.
If you receive an ITAR-controlled item from Globecomm, or receive any technical data regarding an ITAR-controlled item, you must have methods and procedures in place to prevent non-US persons (including your own employees) from having access to those products and technical data. This is because providing access to an ITAR-controlled item or technical data, even while in the United States, constitutes an export.
If you have any questions about whether the Globecomm product you are purchasing is ITAR-controlled, please contact Globecomm’s Trade Compliance team. For more information on the ITAR, refer to the web site at: www.pmddtc.state.gov.
Globecomm is registered with the US Department of State’s Directorate of Defense Trade Controls under the ITAR as a manufacturer and exporter of Defense Articles. Globecomm’s current registration is valid through January 31 and is renewed annually.
For questions about Globecomm products and the applicable export control laws and regulations, please contact our Director of Trade Compliance at: ccantasano@Globecomm.com