Here at L2L, we have a long history of working with customers that are subject to a wide variety of national and international government regulations. In the USA, two of these regulations, ITAR and EAR, govern the export of material goods, technical information, and software.
International Traffic in Arms Regulations (ITAR) is a set of United States regulations to restrict and control the export of defense and military-related technologies to safeguard U.S. national security and further U.S. foreign policy objectives.
The Export Administration Regulations (EAR) are a set of regulations found at15 C.F.R. § 730et seq. They are administered by the Bureau of Industry and Security, which is part of the US Commerce Department. The EAR regulates export and export restrictions: whether a person may export something from the U.S.; re-export something from a foreign country; or transfer something from one person to another in a foreign country. The EAR applies to physical objects - sometimes referred to as "commodities" - as well as intellectual property such as technology and software.
If your company produces products that are subject to either of these regulations, please contact our support team (support@leading2lean.com) to learn more about how we can support your regulatory needs.
L2L Product and Service Classifications
To aid our customers, we have gone through the process of classifying our products and services for both ITAR and EAR. Below are the results of this classification process and what export limitations may apply.
Dispatch Smart Manufacturing Platform https://www.l2l.com/platform
ECCN Classification Number: EAR99
ITAR Classification: Not Required - Not on the U.S. Munitions List
A Web-based SaaS cloud solution used by manufacturers to identify and resolve issues on the plant floor.
Includes modules for Maintenance, Production, L2L Studio (low code application capabilities), and L2L Connect (Machine/API data connectivity, and data visualization).
SensorBot Hardware Device
https://www.l2l.com/connect
ECCN Classification Number: EAR99
ITAR Classification: Not Required - Not on the U.S. Munitions List
A small hardware device that is used for measuring voltages and amps in an industrial environment.
The sensor bots send data wirelessly through the Gateway device (below) to L2L’s cloud services.
Gateway (E-Series) Hardware Device
https://www.l2l.com/connect
ECCN Classification Number: 5A991.b
ITAR Classification: Not Required - Not on the U.S. Munitions List
A small hardware device that is used to receive wireless data from the sensor bots and relay it via ethernet connection to L2L’s cloud services.
Export Implications
Items classified under ECCN 5A991.b or designated as EAR99 require an export license in the following circumstances:
- Destinations subject to comprehensive sanctions or embargo (currently, Cuba, Iran, North Korea, Syria, Russia, Belarus, the Crimea region of Ukraine, and the so-called Donetsk People’s Republic (DNR) or Luhansk People’s Republic (LNR) regions of Ukraine);
- Parties subject to sanctions or trade/export restrictions (see Restricted Party Screening, below); or
- If you have reason to know the item will support a restricted nuclear, missile, chemical or biological weapons proliferation activity.
Items classified under ECCN 5A991.b or designated as EAR99 to all other destinations, valid end users, and valid end uses are eligible for export under the “No License Required” (NLR) authorization.
Restricted Party Screening
Prior to exporting any item, we may perform a restricted party screening against all parties to each transaction. Any potential matches will require additional diligence. The U.S. government’s Consolidated Screening List (CSL) is a list of parties for which the U.S. Government maintains restrictions on certain exports, reexports or transfers of items. The CSL consolidates the lists maintained by the Department of Commerce, Department of State, and the Department of Treasury’s Office of Foreign Assets Control. The CSL can be accessed at https://www.trade.gov/data-visualization/csl-search.