On 1/9/21 12:30 AM, Bernd Neubig wrote:
Björn,
you are correct. The link you have provided points to the actual and latest document of
the Wassenaar Arrangement for so-called "Dual-Use" items.
This international agreement is transformed to National laws, which often
include some amendments.
For the European Union it is the COUNCIL REGULATION (EC) No 428/2009, which is
regularly updated, latest on is the
COMMISSION DELEGATED REGULATION (EU) 2020/1749.
BTAW: For time-nuts the chapter 3.A.1.b is interesting, which covers microwave
and millimeter wave items.
Under sub-clause 3.A.1.b.10 limitations for phase noise of these items are
defined as follows:
Oscillators or oscillator assemblies, specified to operate with a single
sideband (SSB) phase noise, in
dBc/Hz, less (better) than -(126 + 20log10F – 20log10f) anywhere within the
range of 10 Hz ≤ F≤ 10 kHz;
(F is the offset from the operating frequency in Hz and f is the operating
frequency in MHz)
From the technical viewpoint it does not make much sense to specify the phase
noise limits with a slope of -20 dB/decade, while in practice (and theory) the
slope close to carrier is -30 dBc/Hz.
Not too seldom, it is not recognized that this rule is limited to microwave and
millimeter wave oscillators. As the document does not define where "microwave"
begins, this rule is sometimes applied to crystal oscillators below 200 MHz- which to my
opinion is wrong, as microwaves are starting above 1 GHz or so.
Regards
Bernd
Based on my somewhat sketchy and unreliable experience interpreting
export control rules (see digression below) and the knowledge that this
is the province of export control lawyers, not engineers.
This might be interpreted as "oscillators that would/could be used in
microwave or millimeter wave equipment", not that the oscillator itself
is microwave. However, it could also be interpreted as the basic
oscillator (e.g. the VCO in a PLL) performance.
in numbers, for a 100 MHz oscillator , this is -106 dBc/Hz at 10 Hz
offset to -166 dBc/Hz at 10kHz
-----Ursprüngliche Nachricht-----
Von: time-nuts [mailto:[email protected]] Im Auftrag von Björn
Gesendet: Samstag, 9. Januar 2021 06:04
An: Discussion of precise time and frequency measurement
<[email protected]>
Betreff: Re: [time-nuts] ISS NTP operation problems.
Magnus, Warren,
ITAR are US rules for US products. Thus ITAR don’t apply for non US products.
Has that changed?
The original COCOM rule was “don’t do altitude above 18000m and speed exceeding
1000 knots. “
COCOM was then replaced by the Wassenaar agreement. I would have expected it
the current list - but could not find it.
https://www.wassenaar.org/app/uploads/2020/12/Public-Docs-Vol-II-2020-List-of-DU-Goods-and-Technologies-and-Munitions-List-Dec-20-3.pdf
Did I miss it or has it moved somewhere else?
Yes, you're right, it's the Wassenaar *Arrangement*, and more
technically, the two lists, munitions and dual use. (The Wassenaar
Agreement is something about labor laws)
A lot of people (particularly in US) use ITAR (International Traffic in
Arms Regulations) as a catchall word for export controlled, although the
*list* is actually the USML (United States Munitions List), and it's
purely a US thing. And of course there's also the EAR (Export
Administration Regulations) which has the CCL (Commerce Control List).
They're handled by the State Department and Commerce Department
respectively.
And, as an export control specialist explained when I was first at JPL
20 years ago and working on an export license and end-user-certificate
for a TWTA: You are an engineer - the export control regulations were
not created nor are they "understandable" as engineering specifications
or requirements. The determination is made (seemingly arbitrarily) by
someone at State or Commerce. Use the lists as "guidance" but don't try
to lawyer your way through them to find exceptions. This is
particularly true for the EAR/CCL which is often more about trade wars
than "engines of war". It's like the recent tariff stuff - ferrite
cores by themselves, no tariff. Ferrite cores for use in computer power
supplies, 25% tariff. (I might have that backwards) Same exact core part
number, just how it's sold.
Most (but not all) of the Wassenaar munitions list and USML have the
"specifically designed for" clause, which helps a lot with dual use
things like GNSS receivers. Diesel engines designed for submarines -
restricted; other diesel engines - have at it.
The lists have a pervasive effect beyond the obvious. For example, you
will find that there are certain "breakpoints" in data sheet performance
on things like high speed ADCS. You find a lot of 16 bit ADCs that have
sample rates of 65 MSPS. What's special about that particular sample
rate? The part probably runs faster. "3.A.1.a.5.5. A resolution of 16
bit or more with a "sample rate" greater than 65 MSPS;" Likewise, you
see a lot of parts that have 300kRad dose tolerance, even though,
because are bipolar, they are Megarad hard. Why, right there in the USML
there's a restriction on parts that are "rated" at more than 300kRad.
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