Global Trade Policy
It is the policy of Rubicon Communications LLC (“Netgate”), to conduct business in compliance with all applicable export laws and relevant regulations of the United States and all other countries in which Netgate and its subsidiaries and affiliates operate.
Netgate products are subject to the U.S. export controls and sanctions administered by the Bureau of Industry and Security (“BIS”) under the U.S. Export Administration Regulations (EAR), diversion contrary to U.S. law is prohibited.
Prior written authorization from the U.S. government is required for direct or indirect exports and re-exports of Netgate products and technology to any country embargoed or restricted by the U.S. Currently, the embargoed countries are Cuba, Iran, North Korea, Sudan, and Syria. For the most updated information, please review the following sections of the EAR - Supplement No. 1 to Part 740 - Country Groups, and Part 746 - Embargoes and Other Special Controls: https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear.
Netgate products and technology may not be exported or re-exported to individuals or entities listed on the US Government’s Denied Persons List or Entity List as outlined on the BIS website:
Consult the BIS website at https://www.bis.doc.gov/ and the Export.gov website at https://www.export.gov/ for additional information, and the Consolidated Screening List (https://www.export.gov/article?id=Consolidated-Screening-List )
Many Netgate products and software contain encryption. These encrypted products have been reviewed by Netgate or the U.S. government, and qualify for one of the following classifications:
ENC 740.17 (b)(1) Encryption item – Some Netgate products are classified in this category.
ENC 740.17 (b)(2) Encryption item – Some Netgate products are classified in this category, and the exporter is required to obtain a U.S. export license prior to sending a shipment from the U.S. or abroad to certain government entities located outside of the following countries (as listed in Supplement 3 to Part 740 of the EAR): Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Netherlands, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey, United Kingdom. This list is accurate as of the “Last Updated” date at the bottom of this document. It is your responsibility to check for further updates to Supplement 3 to Part 740 of the EAR before shipping.
Please consult with your legal counsel on the export, re-export, and import requirements for encryption products for the U.S. and abroad.
To obtain the export classification for Netgate products—including the Harmonized Tariff Schedule (HTS) number, the Export Control Classification Number (ECCN), the Commodity Classification Automated Tracking System (CCATS) number, and the Country of Origin (COO) - please e-mail your request referenced with the product part number and information requested to firstname.lastname@example.org.
The information provided by Netgate is for general reference only, and is not intended to constitute legal advice. Use of this information by the user is at the user’s own risk. Netgate is not liable for any direct, indirect, or consequential damage incurred by the user or any third party arising from the use of this information on this website. Please consult the applicable export laws and regulations before exporting or using Netgate products.
Last updated on May 20, 2018