> Chapter 3 might be of interest. It has rules on RF amplifiers, arbitrary
> waveform generator, signal analyzers, etc.  I've never looked for
> counters or TICs.

It's been a couple of years since I had to look into this stuff myself, but 
from what I've seen, frequency/TI counters aren't covered by State Department 
ITAR/USML rules unless they're part of a dedicated weapons system.  For 
everything else, you need to search the Commerce Control List _carefully_ to be 
sure of the item's classification.  When in doubt consult an attorney who 
specializes in export law.  The cost of making a mistake can be out of all 
proportion to common sense, and relying on random advice found on the Internet 
(including mine) is a bad idea.  

That being said, you'll find a lot of hits on the CCL for terms like 
"analyzer," "oscilloscope," and "digitizer," but not for "counter."   As Jim 
suggests, commercial electronic equipment generally falls into CCL category 3.  
 The catchall classification for test equipment not otherwise listed is 3A992, 
which requires you to apply for an export license for items destined for Sudan. 
 (Of course, some other countries such as Cuba, North Korea, and Iran will 
require more paperwork regardless of the item in question.)

So as far as I'm aware, unless (a) the specific item is controlled as an ITAR 
munition, (b) you are shipping it to a questionable destination (or knowingly 
causing it to end up there),  or (c) or you are transferring it to someone on 
various official sh!t lists (http://export.gov/ecr/eg_main_023148.asp), you're 
OK.

-- john, KE5FX
Miles Design LLC



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