Cisco's Controlled Technology - Global Export Trade

Controlled technology is subject to national security, foreign policy, and anti-terrorism laws and regulations. Each of us is responsible for safeguarding Cisco design, development, and production technology ("controlled technology") to prevent unauthorized access by countries that have not ratified global weapons nonproliferation treaties. Employees may not electronically, verbally, or physically transfer controlled technology to individuals in these countries unless they obtain written authorization from the Global Export Trade group. (Note: Nondisclosure agreements do not constitute "written authorization.")

Cisco Controlled Technology

The U.S. Export Administration Regulations (EAR) provides that the release of technology or software to a foreign national is an export. A foreign national is anyone who is not a U.S. citizen, U.S. permanent resident alien, or a lawfully admitted refugee or asylee. Exports occur in everyday disclosures of information to a foreign national via consultation, training, company visits, and conversations through e-mail, fax, and telephone.

A U.S. export license may be required before a foreign national accesses certain kinds of software or technology to a foreign national if:

  1. The software or technology is export-controlled and

Controlled Technologies

Technology Regulatory Definition Cisco Product Examples
Total Digital Transfer Rate Exceeding 560 Gbp/s (also known as high speed data transfer rates)

Equipment employing digital techniques designed to operate at a “total digital transfer rate” exceeding 560 Gbit/s (OC-768) Interpreted the speed of a single port that exceeds 560 Gbp/s.
This definition does not include aggregated transfer rate (4 OC-192 cards running at 40Gbp/s would not be subject to this control).

An optional CRS-1 line card, the 1-Port OC-768c/STN-256c POS Interface Card has a single port total digital transfer rate exceeding 15 Gbp/s.
Optical Switching. The routing of or switching of signals in optical form without conversion to electrical signals. The optional ROADM module associated with Cisco's ONS 15454 (MSTP) employs functionality meeting the regulatory definition of optical switching.
  1. The individual is a citizen of one or more of the following countries:

D:1 County Group

Armenia, Azerbaijan, Belarus, Burma, Cambodia, China, Georgia, Iraq, Kazakhstan, Kyrgyzstan, Laos, Libya, Macau, Moldova, Mongolia, Russia, Tajikistan, Turkmenistan, Ukraine, Uzbekistan & Vietnam.

E:1 Country Group

Cuba, Iran, North Korea, Sudan, Syria

Access includes the following:

  1. The release or transfer of technology through 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.

Simply using Cisco products does not fall within the scope of technology and hence is not subject to the regulations described below.

Technology is defined as:

  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, or layouts.
  2. Specific information related to all production stages, such as product engineering, manufacture, integration, assembly (mounting), inspection, testing, or quality assurance; and
  3. Specific information related to an item's operation, installation (including onsite installation), maintenance (checking), repair, overhaul, or refurbishing.

Technology does not include publicly available information, marketing materials, or external or public white papers.

Technology does include "how-to" information, such as Electronic Document Control System (EDCS) documents, comments in source code, conversations, and similar knowledge transfers.

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 as well as access to the latest information on embargoes and denial lists.

Bureau of Industry and Security:

Contact Information

For general inquiries about deemed export issues, please contact the foreign national alias at

Jeno Racz may be reached via e-mail at