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What is “de minimis” and does it apply to FLIR OEM products? If so, how?

De minimis is a percentage-of-content metric used by the U.S. government to determine if an otherwise standalone export-controlled item may be treated differently – for export purposes – if that item is integrated as a component into a higher-level product or assembly. De minimis guidelines can be found here.

De minimis guidelines apply to FLIR OEM products except for the Muon 640 (60Hz), Quark2 640 (30Hz and 60Hz) cameras. These FLIR products are controlled on the International Traffic in Arms Regulations (ITAR) – a set of United States Government regulations on the export and import of defense-related articles and services. ITAR-controlled products are noteligible for de minimis.

The Tau2 640 is export-controlled by the Dept. of Commerce, and considered dual-use items, as are the Tau2 336 and 324 “full-rate” cameras, as well as the Quark2 336.

A fact sheet summarizing export restrictions for Tau 640, 336, and 324 -- both 30Hz and 9Hz models -- can be found here.

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