Author Topic: U.S. ITAR regulations - flir PM695  (Read 9700 times)

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Offline GeodeticTopic starter

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U.S. ITAR regulations - flir PM695
« on: February 28, 2018, 01:59:34 pm »
hello, i'm interested in knowing if the flir pm695 still goes under ITAR export restrictions

thanks to whoever clears my doubt

:)
 

Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #1 on: February 28, 2018, 03:00:55 pm »
The PM695 is covered by both ITAR and the Dual Use Technology Regulations.

It contains a military grade microbolometer that is listed in ITAR regulations under imaging sensors. FLIR can provide the exact reference (ECCN) for the sensor array.  Such equipment remains on the control lists and is unlikely to be removed any time soon.

It is possible to buy such a camera and ship it overseas but the US BIS need to be contacted and paperwork completed. If not in the USA, the local Dual Use technology government department should be contacted in the first instance. Provided the intended recipient is not considered an 'undesirable' by the authorities, they can legally purchase, ship and own such technology.

Many USA based sellers will not ship such technology overseas, or sell to non-US citizens. They fear making a mistake that will land them in trouble.


Fraser
« Last Edit: February 28, 2018, 04:53:31 pm by Fraser »
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Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #2 on: February 28, 2018, 04:47:16 pm »
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Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #3 on: February 28, 2018, 04:55:57 pm »
More guidance......

http://www.oemcameras.com/export_conditions

The PM695 is a 320 x 240 pixel 60fps camera.

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Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #4 on: February 28, 2018, 05:06:01 pm »
Another interesting document, not directly related to the OP's question, but Interesting none the less.

BIS asked for feedback on ITAR from the manufacturing industry. FLIR had a lot to say !

https://www.bis.doc.gov/index.php/documents/pdfs/1662-public-comments-increase-of-controls-infrared-detection-items/file
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Offline Bill W

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Re: U.S. ITAR regulations - flir PM695
« Reply #5 on: February 28, 2018, 07:23:25 pm »
More guidance......

http://www.oemcameras.com/export_conditions

The PM695 is a 320 x 240 pixel 60fps camera.

Fraser

the relevant quote is:
require validated export licenses from the U.S. Department of Commerce

In the context of THAT link (and that link only, not a PM695) it is a commerce license and so is under 'EAR', the US implementation of Wassenaar.  The main point being that over 9Hz means licensed.

THAT link is not ITAR, as that would be a DOD license.

regards
Bill
« Last Edit: February 28, 2018, 07:25:58 pm by Bill W »
 

Offline GeodeticTopic starter

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Re: U.S. ITAR regulations - flir PM695
« Reply #6 on: March 01, 2018, 12:19:35 am »
mh, i knew that and i arranged a shipping with a surplus dealer: i made the seller send to him and he actually sent it...  the problem is that i already have it in hand and i did not compile any submissions.

ALSO i found some sites for surplus like govliquidations, where i saw a Fluke Ti55 , wich is even better than the flir pm695 (in sensitivity though)  and when asked they told me that item was not under any export restriction (to italy anyways).

so i'm doubting the 320*240 60fps IR cameras being under ITAR, and i want to make clear if the intermediary missed something or if the itar changed.
actually do exist cheap 240*320 IR cameras even for 500$
 

Offline Spirit532

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Re: U.S. ITAR regulations - flir PM695
« Reply #7 on: March 01, 2018, 12:43:56 am »
Anything longwave infrared, aside from scanners(as far as I'm aware), that is capable of producing an output(see: FLIR E4/5/6/8 with a 60Hz sensor but locked in hardware to 9) of above 9Hz, requires one or more(depending on the device) license from one(or more) US governmental agencies.
It either falls under ITAR(Dual-Use), EAR(Dual-Use as per Wassenaar), or USML(separate).

Both the PM695 and the Ti55 fall under one or more of these restrictions.

However, as you are in Italy, you are within the European Union(which has more lax regulation), and your country falls under the BIS STA exemption.
See this, page 6: https://www.bis.doc.gov/index.php/forms-documents/compliance-training/export-administration-regulations-training/596-license-exception-sta/file

Therefore, a US seller is authorised to ship a camera to you as the end user(this must be confirmed) without obtaining a license. By shipping it to you without you signing and end-use document(one-sided, no need for approval), as far as my understanding goes, they did break the law, but not as severely as exporting an item without a license.

A lot of these regulations are often broken and ignored - mostly by individual sellers that don't even know they exist(logically, why would you regulate a camera?). Most of the time, nothing bad comes of it, however if one decides to start selling thermal in major quantities, or worse yet - participating in the export themselves(flying out, etc), they can expect to get, at the very least, a bankrupting fine(hundreds of thousands, if not millions of dollars), or at worst, an extreme prison sentence.

Please note that I am neither a lawyer, nor from the US, and therefore might be wrong on some points.


As for 320x240 for $500 - yes, they exist. The Seek Compact PRO FF does 320x240 @ ~15-20Hz(regulated, "X" on the end of product code) or 9Hz(unregulated) for $500. It's a very noisy and small sensor though.
Used cameras can also be picked up for around that much.

« Last Edit: March 01, 2018, 12:49:33 am by Spirit532 »
 
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Offline KE5FX

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Re: U.S. ITAR regulations - flir PM695
« Reply #8 on: March 01, 2018, 01:39:32 am »
Another interesting document, not directly related to the OP's question, but Interesting none the less.  BIS asked for feedback on ITAR from the manufacturing industry. FLIR had a lot to say !

Gotta love our government's position on this.  "Hmm.  It looks like realtime high-resolution IR imaging is becoming more important every day in the civilian sector, due to worldwide development efforts in the autonomous-vehicle field.  Multi-billion dollar international markets are emerging, so we'd better ramp up our export control efforts.  We need to do everything possible to make sure that US-based technology companies are strangled with miles of pointless red tape."

It's almost as if the Chinese and Russians have co-opted the US government, or something.  Huh.  Somebody should look into that.  |O
 

Offline KE5FX

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Re: U.S. ITAR regulations - flir PM695
« Reply #9 on: March 01, 2018, 02:08:45 am »
Refer to a recent post in the same section on this forum, a Chinese company has managed to build microbolometers, and since China is not an ITAR country, that means China can export them to anyone as wish, potentially at lower price. Therefore, there's no point controlling this technology anymore. Instead, US' posture of lifting the restriction and compete with China is not that bad an idea.

That's not what the government was attempting to do here, though.  They proposed to do the opposite, by imposing additional export controls on US manufacturers of widely-available technology.  Read the comments that Fraser linked to.

Obviously these particular comments are almost a year old, responding to a notice of inquiry from the previous administration.  So it would be interesting to know if the Commerce Department (and/or State Department, to the extent ITAR is involved) took the responses to heart. 
 

Offline GeodeticTopic starter

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Re: U.S. ITAR regulations - flir PM695
« Reply #10 on: March 01, 2018, 02:11:04 am »
as from what i saw in their site, the thermal-expert actually can produce 1024*768 too. i did not ask them for the price but i can assume it would be easier to buy a new home XD

they are the $500 device i was talking about...  a extremely good thermal imager with 388*280 resolution and 50mk sensitivity.
they are actuallyu the best i found on the web.

you can pourchase a 640*760  30hz device for 3'500 dollars

i clearly saw some 1024*768 devices in their arsenal. i may be wrong but i'm not sure.
 

Offline GeodeticTopic starter

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Re: U.S. ITAR regulations - flir PM695
« Reply #11 on: March 01, 2018, 02:12:24 am »
so anyways let's say i decide to sell this camera one day i may need to ask a U.S. license?
 

Offline Cerebus

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Re: U.S. ITAR regulations - flir PM695
« Reply #12 on: March 01, 2018, 02:29:46 am »
Refer to a recent post in the same section on this forum, a Chinese company has managed to build microbolometers, and since China is not an ITAR country, that means China can export them to anyone as wish, potentially at lower price.

Allow me to correct, if I may, a little misconception that I see all too often.

ITAR is the United States International Traffic in Arms Regulations. It's just part of US law, a purely American thing. There is no such thing as an ITAR country, ITAR is not an international agreement like the Wassenaar Arrangement* (which indeed covers control of similar materiel). It makes sense to talk of a Wassenaar country (i.e. a participant in the Wassenaar Arrangement), but not an ITAR country.

* Full name: "The Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use Goods and Technologies"
Anybody got a syringe I can use to squeeze the magic smoke back into this?
 

Offline Spirit532

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Re: U.S. ITAR regulations - flir PM695
« Reply #13 on: March 01, 2018, 02:39:30 am »
so anyways let's say i decide to sell this camera one day i may need to ask a U.S. license?

If you're exporting to a country that is not listed by the EC as license-free you would need an export license from them, since you're in the EU.
 

Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #14 on: March 01, 2018, 11:01:24 am »
So in précis.....

The OP bought a PM695 thermal camera and had it shipped to his EU country.
The PM695 most definitely is covered by ITAR and DUT regulations
Destinations that are STA listed countries are far easier to ship to from the USA as they are 'friendly'
The destination recipient needs to be confirmed as a 'friendly' via a declaration  :-DD
Failure to observe the regulations can lead to an investigation and potential prosecution if wrong doing is discovered.

The OP now has the camera so what to do ? .......... IMHO Nothing. It is the shipper who would be investigated for not completing the required paperwork.

What are the implications of 'doing nothing' ? If you contact FLIR and they ask you for your cameras serial number, they may also want your name and location. If such does not tally with their records, they will likely decline to help you and MAY report the location change of the camera to BIS in the USA.

These sorts of camera movements are far from uncommon and I do not see the authorities taking much interest in such as they do not seem to have some ebay auctions pulled as one might expect.

Fraser
« Last Edit: March 01, 2018, 11:43:59 am by Fraser »
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Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #15 on: March 01, 2018, 12:08:59 pm »
As a foot note ......

The ITAR and DUT regulations are not intended to penalise those who need decent thermal imaging technology for their job or enjoyment. They are present to make it a bit harder to obtain advanced dual use or military technology if you are considered an aggresive threat to the USA or other countries. Having such regulations is important if a state wishes to prosecute a person or company that is deliberately supplying inappropriate technology to recipients who would use it against the civilised world. Without such regulations a case of wrong doung cannot be formed by the prosecutor.

It is a fact that advanced thermal imaging equipment can be a great asset in warfare and so it is understandable that some controls over its distribution exist. If I want to buy a top of the range thermal camera with 1280 x 1024 pixels and 120fps from FLIR, I can. No problem, except having to remortgage my house first to pay for it. I am not considered a 'hostile' so the regulations just require that I complete some paperwork. Nothing too onerous I can assure you. I then have a responsibility to keep that camera technology safe within the restrictions applicable to its movement around the world. If I decide to sell it to a NK diplomat in London, I am breaching the regulations and deserve everything that is thrown at me ! Is that so wrong ? If so why ?

Minor movements of relatively simple thermal imaging technology such as Ex fire fighting cameras and older FLIR cameras between 'friendly' countries are unlikely to attract the interest of the State. If I sent my entire collection of thermal cameras to Iran, I might expect a visit from Special Branch. Sounds a sensible response to me.

It is a fact that some people hate regulations and restrictions. To them I say, cool, but do think about why those regulations exist and how lucky we are that, in the case of thermal cameras, they are not too onerous or restrictive. 8fps is plenty enough for many common thermal imaging tasks. I was recently asked what situations actuall required 60fps..... I was hard pressed to come up with good scenarios in daily life that needed high frame rates. Drones and cars were two obvious applications. How many of us will be strapping our cameras to drones and cars though ? It is the fact that it is a 'restriction' that some owners hate. Sadly that is just the world we live in. It can be a very ugly place that requires some controls over some technologies. The regulations are not always perfect, but attempts are made to get them right. The introduction of STA countries in our case.

Regarding China........ China is not a military enemy of the USA or Europe. Yes there are disagreements and issues regarding organised hacking and data harvesting, but China is not a current military threat to the West. They produce a vast amount of high technology equipment for the World abs sometimes have a reputation for putting profit before 'doing the right thing'. That does not mean China is willing to supply advanced military capable technology to countries that the West most definitely have military concerns about. To do so invites unwelcome criticism and sanctions that do nobody any good. Mass production of thermal imaging sensors in China is good for us all, but I believe sensible controls will remain in place where DUT is involved. It is for the benefit of the civilised World after all.

Fraser

« Last Edit: March 01, 2018, 12:11:56 pm by Fraser »
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Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #16 on: March 01, 2018, 12:23:38 pm »
Finally, from me anyway, if the OP or readership ever needs help with the PM695, or any PM series camera, I am happy to provide such. I specialise in repairing FLIR PM series cameras and know them intimately  ;D
I even have stock of the very rare FLIR remote control unit that are available to purchase.

Common age/use related failures include the EVF and Configuration file retention.

They are built like tanks and those who service them for FLIR have nothing but praise for the build quality, stability and longevity. It is rare indeed to have one actually require recalibration. It contains a huge VoX microbolometer and equally large optics. The only issue I have with this model is the carbuncle FLIR added to provide a visible light camera (easily removed or changed if desired). The 'old fashioned' camcorder style suited my use of them but some users prefer an external monitor. Yes they are heavy. That is a result of an all metal construction intended to survive all manner of hostile environs. Some of mine spent their lives in mines yet still perform perfectly and are in good physical shape.

Modern thermal cameras are also excellent. I love my E40 (E60+) but it is nowhere near as ribust as the PM series.

Fraser
« Last Edit: March 01, 2018, 12:26:13 pm by Fraser »
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Offline GeodeticTopic starter

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Re: U.S. ITAR regulations - flir PM695
« Reply #17 on: March 01, 2018, 01:17:13 pm »
as from what i saw i cant be more satisfied from this pm695, stay sure about that. even it weight nearly 3kgs i do move it anywhere. i can't get my hands out of it more than a day XD.
i looked for much many but this came in my wiev and i liked the metal design... i felt its streght even without seeing it in person.

i toy with it really much and i'm looking to make a videorecording option using a beagleboard or similar. i just want to make it be able to record video. actually i dont know where to start tho. if you can link me on this topic i would love you.

i'm also actually stuck on finding a rs232 lemo adapter to connect it to the pc. as from what i know there is software for it bvut i cant connect it to the pc

another thing i'm looking to is a big Ge lens for this camera (around 100 mm with 1.  focal distance )to use it for NETD enhancement. i bought some aga 680 for that purpose but they turned out midwave (my ignorance tho).

and the only area i may sell it to one day is europe, since there are not much of these circulating on european ebay. but selling is not actually a considered option XD
« Last Edit: March 01, 2018, 01:20:44 pm by Geodetic »
 

Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #18 on: March 01, 2018, 03:05:09 pm »
I have the Lemo 2B 310 plug for the PM series cameras and you can communicate with them via simple RS232 commands. They use true RS232 rather than UART levels. A MAX232 deals with the level translation inside the camera.

Sadly the Lemo 2B 310 connector is VERY expensive  :(  I can provide one but will have to see how much it cost me.

For recording the video output, be aware that the cameras come in NTSC or PAL standard. This is changeable via RS232 but the EVF is single standard so will not work if you do change the standard to suit your PVR module. The video output on the is S-Video and Composite. The S-Video is found on the 2B 310 connector but the composite video has its own connector. IIRC it is a lemo 1B 207 type.

As for recording devices for video, there are plenty to choose from on eBay. I use an Archos portable PVR.

If you need to rebuild the battery, it uses standard 'A' size cells but modern 'AA' size high capacity cells can be used.

Fraser
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Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #19 on: March 01, 2018, 03:51:28 pm »
 ;D

Do nothing wrong against your country or its allies and you have NOTHING to fear  ;)

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Offline GeodeticTopic starter

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Re: U.S. ITAR regulations - flir PM695
« Reply #20 on: March 01, 2018, 10:30:05 pm »
what is this list u speak about?
 

Offline GeodeticTopic starter

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Re: U.S. ITAR regulations - flir PM695
« Reply #21 on: March 01, 2018, 10:37:46 pm »
i already regenerated the batteries. i purchased the cellpacks from germany and made sure to reconnect everything as it was.

one thing i would like, is to find more of the internal parts (i detected three pieces wich were not part of the battery pack), that way i could be able to buy even more cells and make more batteries (melting some new containing boxes is a piece of cake) so i just need the internal battery thermometers and whatever else there is (i could just undertsand what's the thermometer)

on the camera i'm mainly interested in the communication between the camera and the pc, and about the video recording. that second thing i would like to be able upload inside the camera itself a suitable app.
i'm sure somewhere someone did hack it upgrading its firmware, that's what i'm looking for :D

 

Offline KE5FX

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Re: U.S. ITAR regulations - flir PM695
« Reply #22 on: March 01, 2018, 10:46:38 pm »
Quote
It is a fact that advanced thermal imaging equipment can be a great asset in warfare and so it is understandable that some controls over its distribution exist.

I remember when the same argument applied to encryption and computers.  It still does, acutally.  Do you feel safer as a result?  It was a silly, naive argument when Playstation 2 CPUs were considered "munitions" by the Japanese equivalent of BIS, and it hasn't become any more relevant over time.

The problem with technology-based export regulations in general is that they only provide a competitive strategic edge if your country is a sole source.  As the documents you linked to illustrate, that doesn't apply here.

Quote
How many of us will be strapping our cameras to drones and cars though ?

All of us who drive cars, eventually. 
 

Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #23 on: March 01, 2018, 11:18:26 pm »
Geodetic,

The PM series are very different to the likes of the Ex and Exx cameras that can be upgraded in various ways. From what I can tell, the PM series cameras run Linux. AFAIK no one has ever hacked a PM series camera. They were extremely expensive when new IIRC $36K and normally operated in industry where hacking is highly unlikely. The one option that would be the target of hacking is the very high temperature mode that is optional. These cameras did not have silly false noise injection or resolution restricters. FLIR made them as good as possible in order to gain market share in the professional marketplace. The PM695 contains a 3rd Generation microbolometer of which FLIR were very proud. With each generation of FPA, FLUR improved the performance and noise figure. They also,improved their noise processing algorithms with each generation of camera. The PM695 has three levels of user selectable noise processing available, as you likely know.

I am not a coder so would be interested in any success you have in accessing the operating system. The main controller board is running a MC68340 and there are two serial ports. One is the remote control port and the other is possibly the engineering port.

With regard to the battery pack. It contains a 10K thermistor, over temperature fuse and over current fuse. These are common safety items in professional battery packs. I purchased the parts to make my own battery packs. I will look at what I purchased for the fuses. Out of interest, where did you buy your replacement cells from in Germany ?

Fraser
« Last Edit: March 01, 2018, 11:22:54 pm by Fraser »
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Offline Fraser

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Re: U.S. ITAR regulations - flir PM695
« Reply #24 on: March 01, 2018, 11:40:27 pm »
KE5FX,

I see where you are coming from with encryption and some processors etc. Public Private Key encryption is very good, if implemented correctly and such 'software' is hard to keep 'contained'.

I feel a little different about decent performance thermal imaging equipment though. They are a lump of hardware that is effective in warfare, plain and simple, No if's, but's or maybe's. If you own a good thermal imaging camera and mount it on a fighting platform alongside suitable weapons, you can be deadly. Have you looked through a military thermal weapons sight recently ? You would be glad that you are on the user end rather than the target that is glowing in the distance and about to be vaporised !

If I were a soldier I would rather the opposition did not have decent thermal weapons sights. It is worth remembering that thermal imaging FPA technology was advanced using large amounts of Military funding, not civilian.

Let's not get too tied up in the politics of whether regulation of this technology is right or wrong though. We are where we are. Common sense is all that is needed to stay out of trouble with the authorities.

Fraser
« Last Edit: March 01, 2018, 11:43:18 pm by Fraser »
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