Global Export Trade

General Deemed Export Information

Introduction

The Bureau of Industry and Security, a division of the U.S. Department of Commerce, is the agency in charge of the development, implementation and interpretation of U.S. export control policy for dual-use commodities, software, and technology. The rules pertinent to export compliance are governed by the Export Administration Regulations.

It is the goal of Cisco Global Export Trade team to observe and comply with all U.S. and international export-related regulations. Global Export Trade actively maintains policies and procedures to help that ensure compliance with deemed export regulations.

Deemed Export Definition

A deemed export release in the United States is a release of technology or source code that is subject to the Export Administration Regulations to a foreign national. Such release is "deemed" to be an export to the home country or countries of the foreign national.

Release of technology includes access by the following means:

  1. Visual inspection (such as reading technical specifications, plans, blueprints, etc.).
  2. Oral exchange of technology, including when technology is made available by practice or application under the guidance of persons with knowledge of the technology.
  3. Posting information on a website or FTP site for downloading.

Technology includes:

  1. Specific information related to all stages prior to serial production, such as design, design research, design analyses, design concepts, assembly and testing of prototypes, pilot production schemes, design data, process of transforming design data into a product, configuration design, integration design, and layouts.
  2. Specific information related to all production stages, such as product engineering, manufacture, integration, assembly (mounting), inspection, testing, and quality assurance
  3. Specific information related to an item's operation, installation (including onsite installation), maintenance (checking), repair, overhaul, and refurbishing.

Cisco's Controlled Technologies

  1. Total Digital Transfer Rate Exceeding 120 Gbps - also known as high speed data transfer rates.
  2. Optical Switching - The routing of or switching of signals in optical form without conversion to electrical signals.

Deemed Export Exemptions

Any foreign national is subject to the deemed export rule except:

  1. A foreign national that has been granted U.S. citizenship.
  2. A foreign national that has been granted permanent residence status (i.e., a green card holder).
  3. A foreign national that has been granted status as a "protected individual" (political refugees and political asylum holders) under U.S. law.

Designated Country Group List

D:1 County Group

  Armenia     Kazakhstan     Russia
  Azerbaijan     North Korea *     Tajikistan
  Belarus     Kyrgyzstan     Turkmenistan
  Burma     Laos     Ukraine
  Cambodia     Libya     Uzbekistan
  China(PRC)     Macau     Vietnam
  Georgia     Moldova    
  Iraq     Mongolia     

* Also an E1 Country

E:1 Country Group

  Cuba
  Iran
  North Korea
  Sudan
  Syria

An individual from Cuba requires a license for employment even if restricted access is not required.

Export Counseling

It is beyond the scope of this site to offer counseling or legal advice on export compliance issues. Please contact the relevant government agencies for counseling and guidance on export licensing and other issues, and for access to the latest information on embargoes and denial lists.

Bureau of Industry and Security: http://www.bis.doc.gov

Contact Information Within Cisco

For general inquiries, please contact the foreign national alias at foreign-national-license@cisco.com. Jeno Racz may be reached via e-mail at jenoracz@cisco.com.