U.S. ITAR regulations - flir PM695

[Geodetic]

hello, i'm interested in knowing if the flir pm695 still goes under ITAR export restrictions

thanks to whoever clears my doubt

[Fraser]

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

[Fraser]

An interesting article on FLIR and ITAR compliance......

http://www.militaryaerospace.com/articles/2009/07/itar-compliance-ignorance-of-defense-export-regulations-is-no-excuse.html

Fraser

[Fraser]

More guidance......

http://www.oemcameras.com/export_conditions

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

Fraser

[Fraser]

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

[Bill W]

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

[Geodetic]

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$

[Spirit532]

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.

[KE5FX]

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. 

[KE5FX]

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. 

[Geodetic]

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.

[Geodetic]

so anyways let's say i decide to sell this camera one day i may need to ask a U.S. license?

[Cerebus]

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"

[Spirit532]

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.

[Fraser]

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 
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

[Fraser]

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

[Fraser]

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 
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

[Geodetic]

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

[Fraser]

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

[Fraser]

 

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

Fraser

[Geodetic]

what is this list u speak about?

[Geodetic]

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

[KE5FX]

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.

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

All of us who drive cars, eventually. 

[Fraser]

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

[Fraser]

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

[Bud]

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

That is an interesting one 

[Geodetic]

i bought the battery packs from akkuplus
they were not much cheap but the material quality satisfied me when i got my hands on them.

if the camera runs linux i may be able to access any time soon, since i'm a student in engineering and linux is one of our studies subject. i'm already posed in programming something on it. dealing with reverse engineering is much easier than making anew. just need to know what is the SO memory occupation, and if i can add data.

i'm not going to get a better optimization via software.. for a 50'000 dollars camera i'm sure it is filled with optimizations.
my intent in accessing the SO is to be able to modify the firmware by adding a "videorecording" option to allow it record videos, obviously in the memory capacities. but actually with 160 mb such as it is the memory, a 240*320 video, if only image, could last really long. a little less if we consider the thermal data too.

once connected to the PC i can easily use some resolution enhancer to get a 640*480

about the NETD i will try someday to use a large lens with close focal distance, when i happen to bump into one cheap enough. if the lens do have larger diameter but same focal distance as the original ones, the NETD will increase drastically.

with a 108mm F 1,8  like the aga thermovision 680 lenses, it may get 50-55 mk.
with a 108mm F 1,0 it could likely get 35 mk.
i already tried here to find some but i found only midwave.. i needed longwave for it.

[Fraser]

Bud,

Meaning NATO 

[Cerebus]

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.

We need a debate from time to time because of the "regulatory ratchet", that tendency for things to be banned, but not to be unbanned when the validity of the original regulation has become dubious, sometimes even farcical. If export controls on CPUs hadn't moved over the years we'd be in the situation where we'd all need end user certificates for our smartphones. Technology moves on in a way that what was only possible to create with a dedicated high-powered, well funded research team twenty years ago is now within reach of a hobbyist or impoverished undergraduate with a few days or weeks to spare.

[Fraser]

Agreed 

[Bill W]

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

The PM695 seems to be a NiMH battery.  In this case the thermistor can do several things.

It can be used to prevent charging / limit charge rate for ambient temperatures, just like a Lithium battery / charger pair should.
Cheap ones do not - sometimes a 10k fixed to make it charge, draw your own conclusions.

It can also be used to end charge as NiMH get hot when nearly charged (dT/dt termination).
Early NiMH were a bit trickier to detect end of charge by the normal voltage drop (-dV/dt) so often used both effects to be sure.

Bill

[Fraser]

Thanks Bill.

I once worked on a professional bit of kit that had the nastiest Nicad charger you ever have seen. It just charged the Nicad pack at a high rate and used a mechanical (bi-metallic) thermo switch attached to the cells to tell the charger to stop the charge cycle. There was no secondary thermal fuse for overheat protection. The batteries used to get very hot indeed and it was no wonder that they did not last long. That was a piece of American kit as well. We changed the charger to a better design and fitted Ni-Mh calls. They lasted until the kit was retired.

The AGEMA PM series batteries are well made but the 4 slot desk charger is hard on them and is known for its unpredictability when it comes to declaring a battery 'faulty' or 'fully charged'. The problem is sometimes poor battery contacts due to corrosion or contamination. Some people scrape the plating off if the contacts and just make a bad situation worse. Thankfully the battery packs are easily rebuilt. New price for a battery from FLIR was £250 + VAT each but I am not sure they can even supply them now. DIY battery casings are a real possibility thanks to 3D printers. Even a suitably sized plastic project box can be used as that is what I used for a while.

Fraser

[Bill W]

I once worked on a professional bit of kit that had the nastiest Nicad charger you ever have seen. It just charged the Nicad pack at a high rate and used a mechanical (bi-metallic) thermo switch attached to the cells to tell the charger to stop the charge cycle.

I recall another, I think it was a drill, that touted its' audible charged signal .... yes you guessed it the bimetallic switch going over and back. 

regards
Bill

[Fraser]

Geodetic,

In case it is of use, here is the communications document for the PM series....

http://support.flir.com/DocDownload/Assets/dl/1557501$a.pdf

I have also just been advised by Spirit532 that the PM and P series are clearly running Win CE. He says it is clear from the GUI but I am not familiar with WinCE so was unaware. It must be WinCE 1.0 in the circa 1997 PM570, and possibly later cameras as well.

Hope this help with your investigations into the firmware.

Fraser

[mikeselectricstuff]

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.

And regs like that can be actively counterproductive in achieving their goal of restricting availability- if people won't buy US sensors because of the hassle of regulations, this means that foreign companies can put more resources into development of more advanced sensors, so it actively increases the availablility to anyone that wants them.

[TheEPROM9]

Does this mean you are not allowed to take high frame rate camera's on holiday. Would be fun to do thermal photography abroad. Or is it just selling the units abroad.

[robert_]

I once worked on a professional bit of kit that had the nastiest Nicad charger you ever have seen. It just charged the Nicad pack at a high rate and used a mechanical (bi-metallic) thermo switch attached to the cells to tell the charger to stop the charge cycle. There was no secondary thermal fuse for overheat protection.

Makita did this as well. Cherger was just a transformer, rectifier, resettable fuse and a latching relay that was reset by the ~45°C bimetallic switch. Charging current around 1C.
It worked surprisingly well and the battery packs dont seem to die, as long as they used robust Sanyo <2Ah NiCd cells. NiMH and chinese noname NiCd didnt like it at all.

[Fraser]

TheEprom9,

The regulations apply to taking controlled across borders so yes, if you take a high frame rate camera on holiday theoretically you could get into trouble if visiting some countries. I presume paperwork for temporary export is needed. I know that a company used to take their high frame rate cameras around Europe and had no issues with such. The USA can be a little more strict though and could, in theory, stop you taking the camera out of the country without correct paperwork. Much will depend upon the attitude is port security staff at points of exit and entry. Most would not be aware of the restrictions on 'civilian' cameras. If they see something that obviously looks Military in nature, the situation could be somewhat different ....... strip search, followed by body cavity search maybe )

The only way to know for certain whether any paperwork is needed for an overseas holiday is to contact the relevant department in both the camera manufacturer and both home and holiday location government export offices. Remember you are effectively 'exporting' when travelling to ans from your holiday location, but involving two different governments.

Also, some common sense applies. I strong suggest that taking a thermal camera to a country that distrusts or dislikes your country of origin is asking for trouble. Accusations of spying using 'sophisticated surveillance tools' is just one accusation that comes to mind.

If I was thinking of taking my FLIR E4 to anywhere in Europe, or surrounding waters, I would have no concerns. I would be a bit nervous of taking any of my military/Industrial looking professional cameras though.

Another important point to remember, if you return to your home country with a very expensive piece of flashy electronics, your countries Customs authority may require you to prove that you have paid the relevant taxes and duties on it or that it was purchased within your countries borders.

Fraser

[Cerebus]

Another important point to remember, if you return to your home country with a very expensive piece of flashy electronics, your countries Customs authority may require you to prove that you have paid the relevant taxes and duties on it or that it was purchased within your countries borders.

If something you have falls into this category, and valuable enough to be worth the effort, it can be a good idea to acquire a carnet (pronunciation: car-nay) for the bit of kit. It's a customs form that proves the origin of an item for temporary import/export and allows you to pass without paying export or import taxes/duty.

An original purchase receipt oftens serves as an informal substitute for getting things back into your country of origin but obviously doesn't cut much ice in terms of temporarily exporting to your destination country.

[TheEPROM9]

Thanks for the info, pretty much all this regulation crap is pretty indecyfrable. Always good to know.

Year when you buy something expensive abraud chuck the box, ding it up a little so it less obvious it is new. Import TAX is a bitch, oftern higher than the usual VAT you would pay normaly. The stuff customs cares about in that catgory is people smugaling rather than someone buying a one of laptop or simular.

Back to thermal cameras, always safer to know & take percausions rather then just clame ignorance as that will rearly help you.

To be honest the restrictions seem pretty poinless if you ask me as as bad acter will alwasy find a way of getting what they want. I am with Mike on this the regs need updating and being made less dreconion, if anything it limits comercial applications as 9Hz is just not enougth for anything video related unless you can put up with lag city. Plus not everyone wnats to make a missial targating system.

[DaneLaw]

Year when you buy something expensive abraud chuck the box, ding it up a little so it less obvious it is new.

Here in  Denmark the customs sadly got access to some registries. (to check VAT&TAX)

Numerous have been speculating in buying expensive stuff when overseas to fx USA, as "USA" is almost China-land in regards to here in the worlds most taxed nation -
-even items that nobody or customs would think twice about a person have on vacation, like laptops, phones etc.
If they sense it perhaps been purchased abroad, and it doesnt matter if you bang it up or use it a lot and make it look like "used".
-they can check the serial to some extent to see if the item have been tax-handled + the mandatory +25% VAT.

Numerous have been caught like that, with mobiles, laptops, even that Mac pro cylinder-computer, which you can also state (it just with me on vacation as its many thousand of dollars you can save)
and it doesnt matter if you make it look used. they sadly got access to some registries to sense if the item has been taxhandled and is legit", - you do risk that the customs will ask for documentation on expensive items, even if its item you already have here in Denmark, (fx purchased privately on ebay and labeled as something else and actually come thrue customs) the moment you then take it out again and back in, if it ain't registered with tax here, you can have a problem.

Actually wondering, have just purchased an Ipad2018 (mainly for my Seek pro) sealed new from an online china wholesaler and purchased it at a price only slightly above US price, and they assured me' that I would not risk any taxing in Denmark when it arrived. (and ýeah, not a problem it came from abroad and then thrue UK and then to Denmark. and it was 25% cheaper than all other alternatives here in Denmark or EU or Apple.dk)
Was somewhat baffled how they could do that and so much lower then everybody else, but since it was thru UK it went straight thru., perhaps they have some firm or Tax/VATaccount in UK, they can tumble to minus and then jump ship.
--
but these ITAR and Wassenaar legislations & agreements..and particularly hence consumer-thermal cams.. have anybody here in newer time' ever heard about anybody in so-called private-regi having federal problems or been fined... ain't it most in theory nowadays.

Noticing many private US-sellers on Ebay is often only valid to ship to US-residents and usually its down to these legislation-hysteria and when asking about (reason) they often don't know why, they have just heard something about sending thermal equipment abroad and don't wanna risk anything' even to one of the most safe and regulated countries on the planet like Denmark who are as "friendly" in a USA viewpoint as they come and one of the founder of Nato since the 40s and likely also part of all the exceptions..
But its a jungle and often confusing, so many US-sellers simply keeping the sale regional-only, even if they gotta admit they could get a way higher price to open up for countries included in the exceptions but they don't wanna risk anything as the US government/bureaucracy is not somebody your fronting...

[Bill W]

Noticing many private US-sellers on Ebay is often only valid to ship to US-residents and usually its down to these legislation-hysteria and when asking about (reason) they often don't know why, they have just heard something about sending thermal equipment abroad and don't wanna risk anything' even to one of the most safe and regulated countries on the planet like Denmark who are as "friendly" in a USA viewpoint as they come and one of the founder of Nato since the 40s and likely also part of all the exceptions..

Ironically Denmark was briefly about the worst place to deal with selling fire cameras like Argus 2 and 3 when they were new.  They used US cores (all of which were from military funded programmes) and the US were tightening up more and more.  The US came up with the great idea that thermal cameras should only be sold to 'Governments'.

The problem was that the Danish fire service were (and I assume still are) the private 'Falck' organisation and are not government like almost anywhere else.  The US could cope with selling to local councils etc but not effectively a car breakdown / insurance company.

Bill

[DaneLaw]

Yes to some extent, Falck = G4S' group4securitas or Falck Securitas = they are the same firm and stands for 60% of danish fire-service according to wiki.
It's a huge many many billion dollar company there stands for many things, Fire-service, ambulance, securities for private or corporates, surveillance & protection, car assist etc etc-
It's also a very old Danish company from the late 1890s or something like that..but I think its been purchase now from England, as their headquarters are in England and also now listed on UK stock exchange. G4S plc or perhaps they just listed in UK for the moment as their headquarters are there.

-damn' according to Falck's own history specs. they are today the worlds biggest security-company and the worlds second biggest private employer in the hole freaking world with more then 600.000 people on there payroll in more then 100 countries around the world.(so its not like its a little player' just doing car-breakdowns.. they are as big as it gets' literally and the worlds second biggest private employer and the worlds frontrunner on securities issues..

Here is there history (though in danish, but google translate wil make it easy to read)
http://www.g4s.dk/Om-G4S/Historie.aspx

It started more then 110 years ago with 4 people riding on their bikes in inner Copenhagen and called nightwatch or in danish "nattevagten".. pretty wicked' they are now the worlds biggest security company and the worlds second biggest private employer.. impressive did recall they where pretty big, but not of this magnitude..

So I doubt that it would be a hassle to sell to the worlds biggest security firm aka Falck G4S, under there home fireservice as they run fire equipment in Denmark with the worlds most advanced and modern firestrucks and fireequipment.(if those Falck claims is still valid, cant say some years since but there gear looks topnotch..)