US Export restrictions on Oscilloscopes to Hungary

[bitbanger]

Hi Folks -

Anyone delve into the maddening world of export restrictions? I'm wondering if the export of an oscilloscope to Hungary (personal sale) is restricted from the US. From ITAR/EAR training I had a long time ago I'm pretty sure a 'scope is considered 'high technology' and thus considered subject to EAR... You would think that this would be easy information to find in this day and age ("we have the technology") but after exhaustive searching and reading on various US sites, including DHS border protection, I can't find any conclusive answer.

Any thoughts? I'd rather skip a potential sale at the risk of something getting held up in customs.

[Keysight DanielBogdanoff]

In my experience, it generally depends on the bandwidth of the scope. Unless you're buying something crazy high bandwidth (>60 GHz) it won't get held up for those reasons. I'd be more concerned with getting hit with import taxes/duties that you weren't expecting, those can often be nasty.

Your safest bet is probably to buy from a local distributor instead of going the private sale/ebay route. But, that's definitely not the only option.

[YetAnotherTechie]

If it's restricted it will show in the customs tariff table. you can also contact the manufacturer mentioning the model and SN and ask what are the Export Control Classification Numbers (ECCNs) and Harmonized Tariff Schedule (HTS) for the specific unit (which you need to know anyway to fill the customs forms). In my experience sending an email with "Export Control Classification Number" in the subject will get you a fast reply from support people...

[bitbanger]

Thanks to both - I should have been more clear this would be me selling to a Hungary resident. Complicating matters also was that I was considering using eBay's "Global Shipping Program". This still requires the seller assure the item is exportable prior to shipping to the GSP hub. The problem I've found (since discovered after reading some eBay forums) is that the GSP folks may very well decide because it is export controlled, and nix the sale and return the item to me (worst case). Because they (Pittney Bowes is the administrator of the program) are the ones then on the hook for the legality of re-shipping it, they are sometimes overly cautious

Anyway seems like more trouble than it's worth.

[bitbanger]

Super helpful info - thanks. I had read the commerce doc (and by read I mean searched for keywords and skimmed it) but wasn't sure how to relate it to specific country. Guess (some of) us Yankees don't deal with exporting enough to understand/decode the system. 

If I were directly shipping, I may heed your advice and press on. However because it's up to the interpretation of Pittney Bowes, I don't want to risk it. I've heard they (global shipping program) sometimes will refund the buyer, let seller keep the payment, and even resell the item domestically. However for "high dollar" items I'm betting they would straight up return the scope to me. I don't feel like being surprised two months from now having to refund >$1k, you know?

Anyway I know I'll likely face this again so thanks again for the info everyone.

Has anyone else dealt with eBays GSP as related to electronic test & meas. equipment? Success/horror stories?

[awallin]

ROHS is more problematic in EU.
I could have bought a couple of LeCroy's or Keysights (malaysia refurb ebay store) already - were it not for ROHS...

[dzseki]

I don't think ROHS is effective on personal  / second hand sales.
My HP 1720A oscilloscope (yeah, I know it's old) is/was an original military item, with AN/USM badge, it even has the barcode for the USAF accession number still on it. The scope came from a hungarian company liquidation sale, so the scope itself probably got into the country in a legal way. So unless the regulations were strictened in the last years I would not fear much.

[CDaniel]

Hungary is in EU  ... the same rules as for Great Britain ( not for long  ) , Germany , France and so on . I really doubt that what you are selling is so important technology that can't be sent ...

[Tepe]

Hungary is in EU  ... the same rules as for Great Britain ( not for long  ) , Germany , France and so on . I really doubt that what you are selling is so important technology that can't be sent ...

Not to mention that Hungary has been a member of NATO since 1999...

[iMo]

An world map is often an useful tool

[Robert763]

Fell across this old thread.
High speed 'scopes ARE export restricted by the USA. High speed is analog maneframes with bandwidth >1GHz, analog Plug ins >4GHz BW. Analog sampling scopes >4Gs/s
Digital sampling scopes 8 bits or more and 1Gs/s or more.
see https://www.bis.doc.gov/index.php/documents/regulations-docs/2334-ccl3-8/file
Specifically 3A992

It's a bit of a minefield. Enforcement is sporadic but penaties can be harsh.
Note that the US consider that these laws apply to US made kit in foreign countries so in theroy you need a licence to export a HP 1Gs/s scope from the UK. I theory if you did and they noticed they could arrest you if you ever entered the USA. 

[syau]

Tektronix is very helpful to provide this lookup engine:

https://www.tek.com/en/support/export-codes

[DaJMasta]

Thanks to both - I should have been more clear this would be me selling to a Hungary resident. Complicating matters also was that I was considering using eBay's "Global Shipping Program". This still requires the seller assure the item is exportable prior to shipping to the GSP hub. The problem I've found (since discovered after reading some eBay forums) is that the GSP folks may very well decide because it is export controlled, and nix the sale and return the item to me (worst case). Because they (Pittney Bowes is the administrator of the program) are the ones then on the hook for the legality of re-shipping it, they are sometimes overly cautious

Anyway seems like more trouble than it's worth.

A year or two ago I sold a 3GHz scope to a person in Ireland through the Global Shipping Program which was caught up in ebay's system for uncertain reasons.  They allowed them to buy it, then didn't let them pay for it, then through an invoice they could pay including a shipping rate through ebay's calculator.... which I could not purchase shipping for even when talking to customer service reps because of an internal block in ebay's system.  It eventually came down to some automated export restriction flag which was completely bogus, but their reps seemed to be unable/unwilling to make it work.

I was also later told that while the global shipping program option can be added to any listing, there's a hard cap in value that they will accept - something like $2000 or $2500 - that you simply can't ship anything more valuable than through it.  So yes, your item could be flagged for non export (though if they are using Buy It Now and can pay, I believe this means it's not flagged, and it's absolutely the case that their automated system misses things), but if it's just high enough price, you can't ship it through the global shipping program at all, and are forced to use the 2x higher rates for another carrier.

From that last pdf of the regulations, I don't think 1GS/s and 8 bit resolution is actually the limitation, but it is the most stringent that seems to address it.  Much more reasonable limits of a 1GHz analog scope, a 4GS/s sampling scope, or a 60GHz bandwidth oscilloscope or scope with more than 6.4Gbit/s continuous recording capability are listed elsewhere in the document.  The 1GS/s rule may be specific to digitizing parts of analog scopes, as it's in the analog scope subheading.

[Njk]

It's a bit of a minefield. Enforcement is sporadic but penaties can be harsh.

It's a minefield indeed. When I was working in the States in late nineties and we're starting a new project, I picked the scope on e-bay, my employer bought it, and when the project was almost done, they gifted the scope to me (a sort of Bravo Award). On my trip home, I simply put it in my bag as a personal belonging. I was more afraid of being charged by the Russian custom. But all went smoothly that time. The scope far exceeded the limits mentioned in the paragraph g. What's the penalty could be for that act in the US back at that time?

---
WBR

[MiroS]

export of an oscilloscope to Hungary

I will be not surprised at all  if Hungary will land soon on very restrictive list

[Kleinstein]

The export restrictions are in some cases rather outdated. I remember having the US version of windows 98 on that list up to around 2001. Such regulations are somewhat slow to change and may thus contain antiques (obesolete, outdated parts) as restricted new technology.

High speed scopes are restricted and from the linkes list the limit would be 1.3 GSPS (even lower for 10/12 bit), so not really that high and even a rather low cost scope from China may be above that limit.
For quite some time not all restrictions were enforced, especially not if an US company sells porducts with restricted parts inside. With the situation with russia they may get more stringent by now.

[jonpaul]

bonjour have benne shipping international for decades, including to Hungary.

1. shipment value <$2500 use EAR99 class

2. avoid any use of epay overseas shipping, very high cost and risk.

3. your local Customs may demand payment of added 20%  VAT on item plus freight.

Better to search on eBay in EU, or local Ham swaps, than ebay US!

very sorry

Best Regards

Jon