Date: 27 Dec 1992 00:08 MST  
From: jms@carat.arizona.edu
Newsgroups: comp.dcom.telecom
Subject: Re: X.25 Switch Vendor Info Please
Reply-To: jms@Arizona.EDU
Organization: University of Arizona MIS Department - Mosaic Group
X-Submissions-To: telecom@eecs.nwu.edu
X-Administrivia-To: telecom-request@eecs.nwu.edu
X-Telecom-Digest: Volume 12, Issue 922, Message 2 of 10

In article <telecom12.919.6@eecs.nwu.edu>, rpw3@sgi.com (Rob Warnock)
writes ...

> jchen@ctt.bellcore.com writes:

>> A foreign company would like to purchase a few small X.25 switches
>> from an US company. I am collecting information for them.

> Be aware that X.25 packet switches fall under the COCOM export
> controls.  You will need an export license, and can't ship at all to
> some countries.  

That's not strictly true.  X.25 packet switches do not fall under
COCOM export controls by name.  However, there are packet switching
technologies which are commonly included in X.25 packet switches which
mean that for some countries (not all), you may have to have a
validated license.  In particular, fast select and high bandwidth
specifications are mentioned.  If you were to implement an X.25 switch
with a total bandwidth below the specs (both pps and bps) and which
did not do fast select, it would not fall under these regulations.

The statement "will need an export license, and can't ship at all to
some countries" is also a little misleading.  For products for which
an export license is required, the license is required.  A better
statement is that some licenses are easier to get than others.
Pointers as to which are easier than others are given in the
regulations, but you can ALWAYS apply (if application is necessary,
which it isn't for all products, countries, or situations, including
things like accompanying baggage and ships stores).

In any case, readers who are interested in working with foreign
nationals, in foreign countries, or in selling equipment abroad,
should consult the appropriate export control regulations and possibly
a lawyer.  Getting free advice (like this) is worth what you paid for
it.

>> In case anyone is interested in seeing the complete text of the new
>> export control regs, they appeared in the Federal Register on August
>> 29, 1991.

This citation is out of date, and was incorrect in any case.  The
current export administration regulations, including the famous
commodity classification list, appear as 15 CFR 770-799, dated January
of the current year.  You also need to know about the munitions list,
which is in 22 CFR 121 (the 121 may be wrong; my handwriting is a
little scratchy here.  But 22 is the right place to start), and
possibly the nuclear rules which are in 10 CFR 110.  (1992 cites;
these may -- but don't often -- change from year to year.)

If you go to a law library to read these -- and they'll be updated to
the 1993 versions very soon -- you MUST also read a document called
"LSA," the List of Sections Affected.  It takes you from the 15 CFR
770-799 to relevant pages in the Federal Register over the past year
which have modified those sections.  That is, to get CURRENT law, you
need to get the published CFR (code of federal regulations) and then
update to the current date by checking the Federal Register (which the
LSA helps by doing a backwards index sort of).  You can usually find
the LSA well thumbed next to the CFR.


Joel M Snyder, 1103 E Spring Street, Tucson, AZ, 85719 
Phone: 602.882.4094 (voice) .4095 (FAX) .4093 (data)
BITNET: jms@Arizona  Internet: jms@arizona.edu  SPAN: 47541::telcom::jms