Packet Forensics products are subject to the export control laws administered by the United States Bureau of Industry and Security (BIS). Their Export Administration Regulations (EARs) provide information on a wide variety of export restrictions and must be consulted if you are planning to export or re-export our equipment or software.

Narrative Explanation

Packet Forensics' devices and embedded software are subject to US export controls and are classified under ECCN 5A002A1 or 5A980 depending upon which firmware license keys are installed as detailed in the table below. Devices and license keys with the least restrictive treatment, those embodying the APK features, were authorized for export under the (B)(1) provision of License Exception ENC on February 5, 2013 as CCATS #G148363. Devices with base (general use) functionality were authorized for export under the (B)(3)(iii) provision of License Exception ENC on April 6, 2011 as CCATS #G136952. Devices and license keys including the more restrictive MLK features were authorized for export under the (B)(2) provision of License Exception ENC on April 6, 2011 as CCATS #G136952. Devices or license keys with the most restrictive treatment, those including the ILK features, are classified under ECCN 5A980 or 5D980A respectively and require licenses in advance of any export. Management software (when shipped standalone on optical media) is subject to US export controls and is classified under ECCN 5D002 and authorized for export under the (B)(2) provision of License Exception ENC on July 7, 2009 as CCATS #G069348.


Table of Products and Export Details

Generally speaking, Packet Forensics may export its products under License Exception ENC to all but a handful of embargoed countries and denied parties. Specifically, our products have been assigned the licensing mechanisms listed in the table below.

Product ECCN Exception CCATS ERN HTS /
Schedule B
Regulation Date Reporting
M-Series
Packet Processor Device
5A002A1 ENC G136952 R100890 8471.41.0150 EAR 740.17(A),
740.17(B)(3)(iii)
April 6, 2011 Semi-Annual
5-Series
Packet Processor Device
5A002A1 ENC G136952 R100890 8471.41.0150 EAR 740.17(A),
740.17(B)(3)(iii)
April 6, 2011 Semi-Annual
Mediation License Key (MLK)
CALEA & European LI Mediation Compatibility
5D002C1 ENC G136952 R100890 8523.40.2020 EAR 740.17(A),
740.17(B)(2)
April 6, 2011 Semi-Annual
Interception License Key (ILK)
Turn-Key LI & Mediation Compatibility
5D980A   G136952 R100890 8523.40.2020 LICENSE REQUIRED FOR ALL USERS / DESTINATIONS April 6, 2011 ADVANCE
Advanced Processing Key (APK)
Communications Modification Capabilities
5D002C1 ENC G148363 R100890 8523.40.2020 EAR 740.17(A),
740.17(B)(1)
February 5, 2013 Annual Self-Classification
5-Series or M-Series & MLK
Device with Mediation License Key installed
5A002A1 ENC G136952 R100890 8471.41.0150 EAR 740.17(A),
740.17(B)(2)
April 6, 2011 Semi-Annual
5-Series or M-Series & ILK
Device with Interception License Key installed
5A980   G136952 R100890 8471.41.0150 LICENSE REQUIRED FOR ALL USERS / DESTINATIONS April 6, 2011 ADVANCE
5-Series or M-Series & APK
Device with Advanced Processing Key installed
5A002A1 ENC G148363 R100890 8471.41.0150 EAR 740.17(A),
740.17(B)(1)
February 5, 2013 Annual Self-Classification
Policy Editor
Device Management Software
5D002 ENC G069348   8523.40.2020 EAR 740.17(A),
740.17(B)(2)
July 7, 2009 Semi-Annual

Additional Export Information

Entities wishing to export or re-export our products are advised to seek their own legal counsel and to consult the US Department of Commerce BIS regulations referenced above.

All 740.17(B)(1) items may be exported to all countries (except Cuba, Iran, North Korea, Sudan and Syria), to both non-government and government end-users No License Required (NLR).

All 740.17(B)(3)(iii) items may be exported to all countries (except Cuba, Iran, North Korea, Sudan and Syria), to both non-government and government end-users No License Required (NLR).

All 740.17(B)(2) items may be exported to Canada to both government and non-government end-users No License Required (NLR).

All 740.17(B)(2) items may be exported to Australia, Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark , Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and the United Kingdom, exports are permitted under License Exception ENC to both government and non-government end-users.

To all other countries (except Cuba, Iran, North Korea, Sudan and Syria), exports are permitted under License Exception ENC only to non-government end-users. Exports to "government end-users" will require an additional, specific export license.

A "government end-user" is defined as "any foreign central, regional or local government department, agency, or other entity performing governmental functions; including governmental research institutions, governmental corporations or their separate business units (as defined in part 772 of the EAR) which are engaged in the manufacture or distribution of items or services controlled on the Wassenaar Munitions List, and international governmental organizations. This term does not include: utilities (including telecommunications companies and Internet service providers); banks and financial institutions; transportation; broadcast or entertainment; educational organizations; civil health and medical organizations; retail or wholesale firms; and manufacturing or industrial entities not engaged in the manufacture or distribution of items or services controlled on the Wassenaar Munitions List."

Export Reporting Requirements

Semi-annual reporting is required for exports under 740.17(B)(2) and 740.17(B)(3)(iii), License Exception ENC for to all destinations other than Canada. Exporters must include for each item, the Commodity Classification Automated Tracking System (CCATS) numbers -- either G136952 or G069348 respectively -- and the name of the item(s) exported (or re-exported from Canada), the name and address of the recipient, the item and the quantity exported. If a distributor is involved, their details must also be reported. If you use a distributor and know who the end customer is, the end customer's details must be reported as well. For exports occurring between January 1 and June 30, a report is due no later than August 1 of that year. For exports occurring between July 1 and December 31, a report is due no later than February 1 the following year. These reports must be provided in electronic form. Reports may be sent electronically to BIS at "crypt at bis dot doc dot gov" and to the NSA at "enc at nsa dot gov". Alternatively, disks and CDs containing the reports may be sent to both of the following addresses:

Attn: Encryption Reports

Department of Commerce, Bureau of Industry and Security
Office of National Security and Technology Transfer Controls
14th Street and Pennsylvania Ave., NW.
Room 2705
Washington, DC 20230

Attn: ENC Encryption Request Coordinator

9800 Savage Road
Suite 6940
Ft. Meade, MD 20755-6000

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