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CNC export regulations - computer numerical control equipment

Golden E. Herrin

There are not many things in life that get more complicated than export regulations, and any company that exports CNC controls or CNC controlled machines has had to deal with the difficult issue of interpreting and applying them. In addition to machine related issues (such as accuracy) which can cause a machine shipment to be restricted, there are three CNC features that will also cause the CNC to be restricted - and, when the CNC is attached to a machine, the entire package (machine and control) becomes restricted. This article discusses U.S. export regulations on machine controls and examines why they exist.

What Is Restricted? There are three machine control features, or capabilities as referenced in the export regulations, that will cause a control to be restricted. All deal with path control and therefore target the more capable CNCs. Functions restricted are:

* More than four axis of simultaneously coordinated axes of motion.

* Real-time processing of CAD data in the CNC for tool path generation.

* Adaptive control with more than one machine condition monitored and fed back to the control for modifying the machining process.

The above restrictions existed under COCOM (Coordinating Committee for Multilateral Export Control) and were retained when the export regulations were restructured under the Wassenaar Arrangement effective November 1, 1996. The name Wassenaar comes from the city in Holland where the final agreement was signed. In the transition from COCOM to Wassenaar, the changes took emphasis off the control hardware and redirected it to the software. The result however is still the same, any CNC having one or more of the restricted capabilities is controlled and as such is subject to export licensing depending on the receiving country.

Why Are There Restrictions? The Wassenaar Arrangement was created by a multination group to replace the procedures that existed under COCOM. COCOM, which expired March 31, 1995, was also a multinational agreement formed in 1949 primarily to prevent U.S.S.R. and its satellite nations from obtaining sophisticated products that could be used to enhance its weapons capability. In its 46 years of existence COCOM had become grossly out-of-date as the landscape of our allies and enemies changed.

Under the Wassenaar Arrangement, Russia has become a member country and the targeted countries, which are not explicitly defined, are essentially pariah countries or "countries of concern." Each Wassenaar participating country is permitted to create its own actions based on "National Discretion." Presently the U.S. pariah countries are: Iran, Iraq, Libya, and North Korea.

What Technology Are We Protecting? Obtaining a U.S. export license for a CNC or a CNC controlled machine that has one or more of the restricted capabilities is a time consuming process that often causes delayed shipments and unhappy customers. In some cases, foreign customers have even stopped soliciting quotations from U.S. machine tool companies for the higher tech machines because of previous bad experiences consisting of delays and licenses turn downs. Instead they have gone to foreign manufacturers where the export rules are interpreted more liberally.

Why is it that the U.S. government risks the loss of export business by applying stricter interpretations to export regulations? It appears that the U.S. Department of Defense (DOD) is the motivating agency in this matter. DOD maintains that all three CNC restrictions are valuable capabilities when it comes to making small, very accurate parts associated with manufacturing nuclear weapons. DOD has been very consistent in their position that the machines with one or more of the three restricted capabilities would be of significant value to non-friendly countries for manufacturing weapon systems that are a threat to our national security.

It is up to the industries affected by export regulations to keep the pressure on government. One of the organizations involved in providing advice to government is the Department of Commerce's Materials Processing Equipment Technical Advisory Committee (MPETAC) which has been working for the past few years to educate government regulators about the changes and the availability of CNC controls. This committee referred to as a TAC committee is sponsored by the Department of Commerce and is chaired by Charles Carter, Vice President of Technology for The Association of Manufacturing Technology (AMT). The industry representatives serving on the TAC continue to work toward achieving a more realistic set of export regulations that will level the playing field with our allies when it comes to international trade.