What thermal camera information is actually restricted by ITAR? - Page 1
Forum section: electronics / general

author: Ben321
author_rank: Frequent Contributor
timestamp: October 05, 2021, 10:17:13 pm
content: I have read that not only is the sale outside of the US restricted by ITAR, so is information about thermal imaging cameras. What kind of information is this? Like the resolution? The frame rate? Is that why some thermal imager camera specs pages seem to be missing information? Sometimes I won't see the resolution of the imager, or if I see the resolution I might not see the framerate. FLIR is usually good about posting both frame rate and resolution for their cameras, but some thermal imaging cameras from other companies like the Raytheon Palm IR250, I can't find one of the most basic pieces of information, the resolution. Is it 320x240? Is it 640x480? I have no idea.

author: jeremy
author_rank: Super Contributor
timestamp: October 05, 2021, 10:36:07 pm
content: In my experience, for stuff that consumers can actually buy, information about the cameras are not really restricted (if they are designed for military applications, that's a different story), but the corporations themselves may restrict information because they are being corporations and they want you to go through the sales department so they can squeeze you for money.ITAR basically restricts the frame rate to 9fps if you don't live in the USA, but in some cases you can sign a declaration to get around this. FLIR cameras also introduce some deliberate noise to the image which I assume is ITAR related. I am not aware of any resolution limits (but they may still exist).

author: Ben321
author_rank: Frequent Contributor
timestamp: October 05, 2021, 10:46:27 pm
content: Quote from: jeremy on October 05, 2021, 10:36:07 pmI think the noise is only for their lowcost ones like the FLIR One. It's done to degrade the quality for low-cost consumer level thermal imagers, that have resolutions comparable to the professional thermal imagers that cost a lot more money. For example, a 160x120 resolution FLIR One Pro costs about $500, but for a professional level camera with the same resolution (but no artificially added noise) costs well over $1000.

author: DaJMasta
author_rank: Super Contributor
timestamp: October 05, 2021, 11:01:47 pm
content: Frame rate is the big one, I believe high performance (cooled) detectors also fall under the category, but I don't think they're generally available at low framerates, so it works as a catch all. 9Hz is the limit, and the EU has a nearly identical restriction that prevents European competitor's cameras from being easily imported to the US.... it's a bit of an odd situation.Being ITAR restricted also doesn't mean that they can't be shipped overseas, it just means that both the shipper and receiver have to be appropriately documented and allowed to have the equipment, making it much more costly/difficult to export and basically letting the government have some tracking on what is considered potential military equipment. You can find a good number of ITAR restricted thermal cores outside of the US, they're just generally not as available.

author: jeremy
author_rank: Super Contributor
timestamp: October 05, 2021, 11:05:03 pm
content: Quote from: Ben321 on October 05, 2021, 10:46:27 pmThe pro cameras do definitely still have artificial noise added, I have observed it on a $6k camera (non-USA edition of course).

author: Fraser
author_rank: Super Contributor
timestamp: October 05, 2021, 11:10:55 pm
content: We need to be clear on terms being used here….ITAR relates to items on the Military List whereas items that are “Dual Use Technology” come under the jurisdiction of BIS or the equivalent outside the USA. The two sets of regulations pertain to very different equipment in most cases as Military kit is understandably closely controlled.ITAR can apply to a part, a subsystem or the sum of parts. That is to say, it can cover just a sensor array or the combination of a number of parts that form a capability. If the sensor array appears on the Military list then any equipment that contains that sensor automatically becomes liable to ITAR regulations.Where “Dual Use Technology” is concerned, it is little different to the controls placed on the export of some high performance processors etc. The capability of the equipment dictates that it’s distribution be controlled to prevent ease of access by parties considered undesirable end users.So what restrictions apply to discussing equipment that is ITAR or Dual Use Technology controlled distribution ? Well in the case of ITAR just about all deep technical information, such as schematics and possibly in depth specifications will be controlled. Even the block diagram or description of circuit operation is usually controlled. If you look on a Military supply organisations web site you will often see flashy brochures but if technical information is needed you are told to contact them for approval etc. With Dual Use Technology the situation can be the same, or a little different, depending upon the technology involved. Even commercial products often have controls on release of deep technical information, schematics and description of circuit operation. Just look at the FCC ID database to see how most companies request that technical information on a design be kept confidential. With thermal imaging we have seen products move from the realm of Military use to Civilian use but historically the deep technical detail of equipment design has been a closely guarded secret within companies making such specialist equipment. The detailed data sheets for US sourced microbolometers have been mostly kept out of the uncontrolled public domain as they share a lot of features with those used in Military applications. Some are even used in both Military and civilian equipment so there can even be ITAR involvement. ULIS appear to have been less concerned regarding discussion of microbolometer design and operation and have presented detailed documents to seminars and on the internet. The datasheets for ULIS microbolometers remain corporate sensitive and are supposed to be supplied under NDA but many have appeared on Chinese web sites, so document control at ULIS has failed !Thermal imaging technology has become far more common and ‘main stream’ in the last decade or so. As such there are an awful lot of cameras in the public domain that may be reverse engineered if desired. Such action is not illegal but I personally would be a little careful divulging much deep technical design information from a high end Industrial thermal camera that shares capabilities and features found in Military applications. Most consumer grade thermal cameras are actually not that exciting in terms of design and so may be considered little more than commercial sensitive. The deep detail of how the microbolometer is constructed may still be considered more sensitive but Honeywell described the basic design many years ago and it will be the clever enhancements and refinement of the ROIC that likely attracts more sensitivity and control for both Dual Use Technology and Corporate Confidentiality reasons.Hope this helps.Fraser

author: Fraser
author_rank: Super Contributor
timestamp: October 05, 2021, 11:20:56 pm
content: Regarding artificial noise …… this has nothing to do with ITAR or Dual Use Technology regulations and everything to do with the Marketing team !In the case of FLIR, an artificial noise generator is used to degrade the performance of a lower specification camera. It is an easy way to offer several different cameras with differing specifications for Noise at different price points yet using a single platform. Other differences will include the feature set provided with each camera model in the range. Where there are two different camera ranges, it is not unusual for a very similar or identical sensor array to be used and the back end electronics may also be of similar performance. In such a case FLIR want to ensure that the lower priced range does not compete too heavily against the cameras in the higher range so they keep a level of noise in the lower range cameras to artificially separate the two camera ranges noise performanceMarketing, Marketing, MarketingExamples are…. FLIR E4 had a lot of artificial noise injected into its image. The top of the range E8 had less noise injected but still had some present. The E30 had a lot of noise injected into its image and the E60 has much less artificial noise injection but still some so that it did not compete too heavily with the Txxx and Bxxx ranges above it. As part of the Ex and Exx upgrade we switch off the artificial noise generator as it is just a configuration option that may have its level set or may be switched off completely.

author: Ben321
author_rank: Frequent Contributor
timestamp: October 05, 2021, 11:21:09 pm
content: Quote from: Fraser on October 05, 2021, 11:10:55 pmSo info about the frame rate and resolution is not usually controlled? It's usually more circuit-level information that's controlled?Also you make a distinction between if it's dual use or ITAR, but most websites that sell 9Hz thermal cameras (rather than 30Hz) always say they do so to avoid violating ITAR, even for consumer grade cameras.

author: Ben321
author_rank: Frequent Contributor
timestamp: October 05, 2021, 11:25:33 pm
content: Quote from: Fraser on October 05, 2021, 11:20:56 pmI thought only the FLIR One series had noise added, compared with more expensive thermal cameras like the E4, while E4 up through the Txxx range I assumed all had no noise injection, and only differed by resolution, frame rate, whether or not wi-fi was available, and the number of features present in their menus.I've heard the E4 has a hack available to give it full resolution. Does this hack also remove the artificial noise?

author: Ben321
author_rank: Frequent Contributor
timestamp: October 05, 2021, 11:31:11 pm
content: Quote from: DaJMasta on October 05, 2021, 11:01:47 pmMaybe there's a restriction between the manufacturer and an over-seas end user, so the manufacturer needs certain paperwork from the end user to prove it's legal to ship it to them. So what happens when the end user no longer needs it after several years, and puts it up for sale on eBay? Maybe if a person did that in the US they could get in legal trouble, but if the person legally receiving the camera was overseas, they couldn't get in trouble from reselling it, because overseas isn't in the US jurisdiction. You can't be guilty of violating a US law if you aren't in the US. Then it can end up pretty much anywhere in the world. It doesn't seem that ITAR then is actually a secure legal mechanism for preventing distribution of sensitive technology.

author: Fraser
author_rank: Super Contributor
timestamp: October 05, 2021, 11:31:18 pm
content: Frame rate and resolution specifications are not normally considered sensitive EXCEPT where Military equipment is involved. In a Military setting you do not give away your equipment capabilities for obvious reasons.ITAR relates to the Military list. The frame rate of a camera can lead to its inclusion on the Military List but more often in commercial camera equipment it is about the Dual Use Technology capability and the frame rate limitation permits easier distribution under the relaxation of the regulations pertaining to thermal imaging cameras that are deemed less likely to pose a serious threat to a nations armed forces. It is open to discussion whether 9 FPS still makes a decent targeting sight but I will not go down that Rabbit Hole here !I am guilty of using the term ITAR when it is not the correct terminology and the error stems from my past involvement with ITAR liable equipment. Bill_W has had to correct me on several posts where I said ITAR when I should have said Dual Use Technology Regulations. It can be hard to determine whether a particular thermal cameras sensor array is ITAR controlled but I own several industrial thermal cameras that have a label on them warning that they contain ITAR liable sensor arrays. Those cameras use the same sensor arrays as some Military kit so are detailed in the Military List. Another similar sensor array may not be ITAR Controlled because of different (lesser) capabilities or more commercial sector origins with no Military development input.

author: Fraser
author_rank: Super Contributor
timestamp: October 05, 2021, 11:53:28 pm
content: FLIR One uses the Lepton core and it is sadly a noisy beast so FLIR did not need to add any noise to degrade its performance…. It was already “Marginal”As mentioned, the venerable E4 has noise added to degrade its noise performance compared to the E5, E6 and E8. Just look at the data sheets for these different models and note the noise levels. The differences between them are artificially created by the software noise generator setting. As part of the upgrade the noise generator is switched off completely, so the camera provides the best possible noise performance….. even better than a standard E8The E8 still has noise injected into its image to degrade it compared to cameras within the Exx range so even an E8 can be improved by the upgrade process. The E4 upgrade covered Resolution, Noise Generator disablement and the addition of many features normally only found on the Exx and Txxx series cameras

author: Fraser
author_rank: Super Contributor
timestamp: October 06, 2021, 09:49:04 am
content: Some information from BIS on Dual Use Technology…..https://www.bis.doc.gov/index.php/licensing/forms-documents/.../91-cbc-overview

author: Fraser
author_rank: Super Contributor
timestamp: October 06, 2021, 09:53:59 am
content: Some useful information on the US Munitions List (ITAR) and the Commerce Control List (EAR)(I call them the Military list and Dual Use Technology in my previous comments)https://research.ncsu.edu/administration/compliance/research-compliance/export-controls/export-controlled-items/

author: Fraser
author_rank: Super Contributor
timestamp: October 06, 2021, 10:03:45 am
content: A useful tutorial on ITAR and the US Munitions listhttps://www.sbir.gov/tutorials/itar/tutorial-1An excerpt, below, discusses ITAR liable technical information and software…….“Another cornerstone concept is that these controls apply not just to physical products, but also to software and technical data, as well. So, if an item is on the list such as a navigational device - the software used to run that device is also on the list, and the technical data related to the device is on the list. Technical data refers to drawings, algorithms, manuals, any information on the design, manufacture, or use of the item. So, if the product is on the list, then the electronic files are on the list, the specification sheets, the technical manuals – are all on the Munitions List and subject to ITAR. These items are subject to the same sets of controls under ITAR as physical products.”

author: Fraser
author_rank: Super Contributor
timestamp: October 06, 2021, 10:18:15 am
content: An interesting BIS document (FAQ) discussing the release of information in differing scenarios…….https://www.bis.doc.gov/index.php/documents/compliance-training/export-administration-regulations-training/1554-ear-definitions-faq/fileNote: This is from 2016 so may not be the latest version.

author: JoshuaOne
author_rank: Newbie
timestamp: October 06, 2021, 08:11:16 pm
content: Good morning.This probably seems like a silly question, but I spent the better part of five hours between last night and this morning hunting for a clear answer.Here’s my question, under ITAR, relating to thermography, what is the qualifier for exporting training or skills?Here’s what I mean. I have a pulsar Helion thermal imager. Commercial unit, available freely over the counter, hundreds of videos shot with it online and on YouTube. Mostly hunters, but some tactical stuff too. Any of those videos could arguably be used to augment understanding and use of the unit, or could be considered training materials or supporting skills development by a foreign entity. So why are they not prosecuted under ITAR? Is the restriction void if it’s publicly available equipment? Does that mean anything filmed with it is also okay? Since the filming through it and posting it online has been done so by the manufacturer and countless other companies and individuals?For me, I enjoy playing with thermals and night vision. I do not post technical data that has not been posted publicly by the manufacturer. I have fun seeing how things appear on thermal, and have filmed everything from a skunk trying to get to my chickens, to rain drops, to my dogs footprints left behind, and uploaded them. I feel this is all safe as i can’t see any military application. But I also have fun trying to beat the sensors and hide from the tech. I don’t test any materials which themselves could be considered defense articles, with the sole exception being showing what surplus uniforms freely available to the public look like on night vision under IR illumination. But that’s in the public domain to my understanding. I don’t film proprietary materials or restricted defense articles. For example, I basically kind of run a “myth busters” type channel. Someone says a space blanket hides you on thermal. I film it and show what it actually looks like. Some things work, like firefighter gear under camo uniform, some things kinda work, like radiant barrier and bubble wrap (lol), and some things block signature but create one of their own which is just as obvious as the persons thermal signature, like the space blanket.I was cruising this forum last night just reading because it’s a subject that fascinates me, and I saw several mentions related to technical data disclosures. I looked up the actual text of ITAR, tried to find definitions for operation, training, skills development, real world operation, and tried to find case law for prosecutions under the section to figure out what exactly is prohibited.From what I could gather, using a freely available commercial product to film any manner of non defense articles not subject to secrecy clause or classification themselves is fine. But I really don’t want to go to prison for twenty years because I filmed an umbrella and found it hid a person from the sensor and the state department determined that represented training a foreign national in operation of the unit.Thank you for any input.-Joshua

author: Bill W
author_rank: Super Contributor
timestamp: October 06, 2021, 08:48:14 pm
content: Quote from: JoshuaOne on October 06, 2021, 08:11:16 pmSimply the Helion is not an ITAR product, it is a dual use (Wassenaar Agreement) level product.Remember that ITAR stands for International Traffic in Arms Regualtion, it is a US regulation managed by the US Dept of Defense . It deals with items specifically designed or modified for military use.In the UK the equivalent is the 'Strategic/Military list' where the authority is the Ministry of Defence, and the same applies to most NATO aligned states.Dual use (Wassanaar Agreement) items in the US are managed by the Dept of Commerce through BIS and the EAR (Export Authorisation Administration), UK it is Dept of Trade & Industry also through a BIS section. Oddly the EU has one dual use control directive for the 27, enforced at the nation state level, but Military list control is only done at nation state level.One of the standard examples in training is the steering wheel for a jeep.Normal steering wheel - commercial item.Steering wheel on a green painted jeep - still commercialSteering wheel for a ex-military jeep - might be dual use as it enables a military jeep to be repairedSteering wheel with a fitting for a gun recoil shock absorber - military controlled item. It is specifically adapted for a specific military use - ie to resist large calibre gun recoil.As a manufacturer when attempting to export your new camera design it will be assessed for 'military usefulness' and either come back as 'Military list' or 'Wassenaar'. There is no one specific technical feature to decide that, but there are specific technical features that can exempt a design, such as <9Hz or vehicle linked.The 9Hz 'thing' is specific to Dual use Wassenaar items. A decision was made that below 9Hz image refresh an imager ceased to be "militarily useful" and hence could no longer be 'dual use'. Therefore 9Hz and under is a pure commercial item, no restrictions (except N Korea etc). I, and others, may see a number of flaws in that argument but it was voted through. What that immediately does mean is that any information that would allow a 9Hz upgrade isby definitiona militarily useful piece of information.Bill

author: Bill W
author_rank: Super Contributor
timestamp: October 06, 2021, 08:59:18 pm
content: Quote from: Ben321 on October 05, 2021, 10:17:13 pmAny 'militarily useful information' is restricted, maybe by ITAR, maybe by EAR (for US application). Pixels, frame rate, focal length and field of view are not such. Vibration resistance, enhanced recoil protection options and how to wire it to a cruise missilewill be restricted.Palm IR 250 is fully specified online for pixels and frame rate, but as it is quite old many links are dead now. Line 1 of Google search, 3 on DDG for me.

author: Bill W
author_rank: Super Contributor
timestamp: October 06, 2021, 09:47:27 pm
content: Quote from: Fraser on October 05, 2021, 11:10:55 pmOr the Chinese interpretation of 'NDA' is copy and post where you like as we do not respect NDA's.It is if you like the cost of doing business in China (as ULIS are/were) that all your documentation will be copied and made (Chinese) public, to aid any state enterprise that fancied copying it.One ironic aspect was the Chinese copying the ULIS packaging - which was not exactly the best early on.Bill

author: JoshuaOne
author_rank: Newbie
timestamp: October 06, 2021, 11:16:45 pm
content: Perfect. I appreciate your time and the detailed response greatly. Thank you very much. Now I’m not so worried I’m going to go to prison over a backyard video wearing firefighter pants. Lol!

author: ixfd64
author_rank: Frequent Contributor
timestamp: October 31, 2021, 08:52:04 pm
content: I noticed that a lot of sellers won't ship thermal cameras outside the U.S. even though ITAR does not prohibit such exports. It is my understanding that the seller only has to fill some paperwork for an export license and submit it to the BIS. Does this process usually take a lot of time? Or are there other regulations besides ITAR that affect the export of thermal cameras?

author: Bill W
author_rank: Super Contributor
timestamp: October 31, 2021, 11:48:55 pm
content: Quote from: ixfd64 on October 31, 2021, 08:52:04 pmEAR for dual use stuff is indeed just paperwork, and can be simple enough if you are a company set up for it. Equally there can be quite a lot of it and many will just 'not be bothered with so much darn Gummint ****'. There's 400M+ potential custoemrs so why bother ?Quite how much paperwork will depend on the device, the volumes, the seller and the customer. There are no specific rules on what the conditions of the license will be, and EAR can (try) to apply further conditions on the customer which may make the seller feel exposed.Anything that came into ITAR (primarily of military use) would be a lot more onerous.

author: ixfd64
author_rank: Frequent Contributor
timestamp: November 01, 2021, 01:06:56 am
content: I'm guessing for private sellers, it's more of a matter of not wanting to deal with the paperwork rather than not being allowed to export the device.