Comtech EF Data :: Export Compliance

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As one of the leading manufacturers of digital and RF Products, including data modems, low noise amplifiers, solid state amplifiers, RF up and down converters, redundancy subsystems and complete data TX/RX terminals, for the satellite communications industry, Comtech EF Data Corporation (the Company) takes its position as market leader and corporate citizen with the utmost seriousness. Recognizing that the illegal diversion of high technology commodities and technical data to military, terrorist, or nuclear/missile/chemical weapons proliferation activities poses a serious risk to the national security of the United States, as well as other nations in which the Company does business, and since export control regulations apply to virtually every aspect of our business, the Company has and will maintain a strict export control policy.

Export Control Statement

Each sales order acknowledgement and invoice contains the following statement:
THESE COMMODITIES, TECHNOLOGY OR SOFTWARE WERE SHIPPED DOMESTICALLY AND/OR EXPORTED FROM THE UNITED STATES OF AMERICA IN ACCORDANCE WITH THE EXPORT ADMINISTRATION REGULATIONS. DIVERSION CONTRARY TO U.S.A. LAW IS PROHIBITED.

Jurisdiction

Comtech EF Data products have been reviewed and classified by the US Department of Commerce (DOC) and are subject to the Export Administration Regulations (EAR) administered by the Bureau of Industry and Security (BIS). The EAR can be reviewed at the following web address: http://www.bis.doc.gov/

Export Classification Control Number (ECCN)

For a complete listing of ECCN by model number: View a list by model number

Schedule B Numbers for Export/Harmonized Tariff System Numbers for Import

Product	Schedule B	HTS
Digital Products (Modems, Switches, etc.)	8517.62.0050	8517.62.0050
RF Equipment (Converters, LNAs, Transceivers, etc.)	8527.99.3060	8527.99.3060
Warranty Returns/Repairs	9801.10.0000	9801.10.0000

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Prohibitions

Embargoed/Sanctioned Nations – The US Department of Treasury’s Office of Foreign Assets Control (OFAC) maintains the listing of nations under embargo or sanction of US Goods. Comtech EF Data products are prohibited from shipping to the following countries:

Cuba
Iran
North Korea
Sudan
Syria

Please refer to the OFAC web address for additional details: http://www.ustreas.gov/offices/enforcement/ofac/programs/

General End User Prohibitions

The US Government places export controls on certain nations principally due to national security. In addition, the EAR places limits on products being used in some of the following activities:

Missile technology
Foreign military applications
Nuclear proliferation
Drug trafficking
Terrorism, etc.

Please refer to EAR Part 736 for more details at web address: http://www.access.gpo.gov/bis/ear/ear_data.html

Prohibited Parties Listings – Various US government agencies publish lists of persons and companies that are denied US exports and will require licensing from the appropriate authority prior to export or re-export:

Denied Parties – DOC (BIS)
Special Designated Nationals (SDN) – US Department of Treasury (OFAC)
Entity List – DOC (BIS)
Unverified List – DOC (BIS)
Debarred List – Department of State (DOS)

These lists are accessible through the DOC/BIS web address under the Exporter Resources – Lists to Check: http://www.bis.doc.gov/

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Violations

Comtech EF Data Export Controls Group will report any known violations to the appropriate government agencies: DOC Office of Export Enforcement (OEE), Department of Homeland Security US Customs and Border Protection (CBP), or US Department of State.

Customer Purchase Order Requirements

All customer purchase orders must include the following:

End User Name (Address if available)
End Use Country
Clear (Foreign) Ship To Address (if goods are for export)

Note: All Exports from the USA require a commercial invoice. Comtech EF Data will not release shipments to freight forwarders or carriers without a Comtech EF Data commercial invoice or drop ship document provided by the customer.

Questions/Contacts

Comtech EF Data Export Controls Group is available for questions or concerns:

Cheryl Crow – Director, Logistics (Empowered Official)
Phone: 480-333-2187
Fax: 480-333-2470
Email: ccrow@comtechefdata.com

Richard Estrada – Export Coordinator
Phone: 480-333-2332
Fax: 480-333-2470
Email: restrada@comtechefdata.com

Esther Dixon – Compliance Manager
Phone: 480-333-2550
Fax: 480-333-2470
Email: edixon@comtechefdata.com

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Notice: Comtech EF Data reserves the right to change specifications of products described in these documents at any time without notice and without obligation to notify any person of such changes. Information in these documents may differ from information published in other Comtech EF Data documents.