ITAR EAR & Export Compliance

Thermal Bros Customer Resource

A plain-English overview of U.S. export considerations for thermal optics, night vision devices, clip-ons, weapon-mounted optics and related equipment.

Customer education Official government resources Last reviewed July 29, 2026
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Do not assume every thermal or night vision product has the same classification.

Export requirements can depend on the specific item, technical specifications, classification, destination, end user and intended end use. This page provides general customer information and is not a product classification, export authorization or substitute for legal advice.

Why export compliance matters

Thermal imaging devices, night vision equipment, clip-ons, certain weapon-mounted optics, lasers and related technology can be subject to United States export controls.

An export can include more than placing an item in an international shipment. Depending on the applicable regulations, taking an item outside the United States, transferring it to another destination, or releasing certain controlled technical information can also create export compliance obligations.

The fact that a product is commercially available, used for hunting, purchased legally or owned by a private individual does not by itself determine whether the product may be exported.

Thermal Bros’ approach

Thermal Bros is committed to complying with applicable U.S. export control laws and regulations. We may review, delay, decline or cancel a transaction when the destination, purchaser, end user, end use, payment information, freight-forwarding arrangement or other circumstances create compliance concerns.

Thermal Bros does not authorize customers to export products and does not represent that any product may be shipped, transferred or carried outside the United States without further review.

ITAR and EAR in plain English

These are separate regulatory systems administered by different U.S. government agencies.

ITAR

The International Traffic in Arms Regulations are administered by the U.S. Department of State’s Directorate of Defense Trade Controls.

  • Applies to defense articles and defense services designated on the U.S. Munitions List.
  • Can also cover certain related technical data.
  • Classification depends on the actual article or service—not simply its retail category or product name.
  • Questions about State Department jurisdiction may require a formal Commodity Jurisdiction determination.

EAR

The Export Administration Regulations are administered by the U.S. Department of Commerce’s Bureau of Industry and Security.

  • Covers commercial, dual-use and certain other items under Commerce jurisdiction.
  • Items may have an Export Control Classification Number, commonly called an ECCN.
  • Some items may be designated EAR99 when they are subject to the EAR but are not listed under a specific ECCN.
  • Being subject to the EAR does not automatically mean an export license is required.
“ITAR controlled,” “subject to the EAR,” “EAR99” and “license required” do not mean the same thing.

What this means for customers

Consider the complete transaction—not only where you purchased the product.

Domestic purchase

Buying within the United States

A normal domestic purchase does not automatically authorize a later export, international transfer or foreign use of the product.

International shipping

Mailing or shipping equipment abroad

Sending an item outside the United States is an export. Applicable requirements must be determined before the shipment is arranged.

International travel

Taking equipment on a trip

Carrying an item outside the United States can constitute an export even when you plan to bring it back after your trip.

Transfers

Reselling, lending or giving away equipment

A resale, loan, gift or transfer can raise export concerns when it involves a foreign destination, foreign party, restricted end user or prohibited end use.

Freight forwarding

Using another address or forwarding service

A domestic delivery address does not eliminate export obligations when the item is ultimately intended for another country.

Technical information

Sharing controlled technical material

Depending on the product and information involved, certain controlled technical data, technology or source code can also be subject to export restrictions.

Before traveling internationally

Do not wait until you reach the airport, border crossing or shipping counter to investigate export requirements.

Ownership is not export authorization.

Legally purchasing a product in the United States does not automatically authorize you to take it to Canada, Mexico, Europe, Africa or any other international destination.

  1. Identify the exact product. Record the manufacturer, model, specifications, serial number and included accessories.
  2. Obtain classification information. Request written export classification information from the manufacturer or pursue an official agency determination when appropriate.
  3. Review the destination. Requirements can differ by country, including countries that may otherwise be common hunting or travel destinations.
  4. Review the end user and end use. Who will possess the equipment and how it will be used can affect the transaction.
  5. Confirm whether authorization is required. Determine whether a license, license exception, exemption, temporary authorization or other documentation applies.
  6. Keep supporting records. Carry and retain applicable classification, license, exemption, customs and temporary export documentation.

Frequently asked questions

These answers provide general guidance and are not product-specific export determinations.

Are all thermal scopes controlled under ITAR?

No blanket statement should be made for every thermal scope. Depending on the item and its specifications, a product may fall under State Department jurisdiction, Commerce Department jurisdiction or another classification. Obtain reliable classification information for the exact product.

Does “subject to the EAR” mean that a license is always required?

No. Being subject to the EAR and requiring an export license are separate questions. License requirements may depend on the product’s classification, destination, end user, end use and any available license exception.

Can I take my thermal scope on an international hunting trip?

Taking an item out of the United States can constitute an export, even when the item will return with you. Confirm the exact product classification and all applicable requirements before traveling.

Can I take thermal or night vision equipment to Canada or Mexico?

Travel to a neighboring country is still international travel. Do not assume that driving across the border or carrying the equipment personally eliminates U.S. export requirements or the destination country’s import requirements.

Can Thermal Bros ship my order internationally?

International transactions require additional review and may be declined. Do not place an order using a freight forwarder, alternate recipient or domestic forwarding address to bypass export restrictions or Thermal Bros policies.

Can I send an optic to an international hunting guide or outfitter?

Sending equipment to a guide, outfitter, lodge, friend, family member or other recipient outside the United States is an international shipment and may require authorization. The recipient’s role does not remove export requirements.

Can I resell or loan my optic to another person?

Domestic resale or lending is not automatically an export, but additional concerns can arise when the recipient, intended destination, end user or end use involves another country or a restricted party. Do not participate in a transaction intended to avoid export controls.

What is an ECCN?

An Export Control Classification Number identifies certain items on the Commerce Control List. The ECCN is used with destination, end-use and end-user rules to help determine applicable export requirements.

What does EAR99 mean?

EAR99 generally refers to an item subject to the EAR that is not specifically described under an ECCN on the Commerce Control List. EAR99 does not mean that every transaction is permitted; destination, restricted-party and prohibited end-use rules can still apply.

Can Thermal Bros provide a legal classification for my product?

Thermal Bros may be able to share classification information supplied by a manufacturer, but we do not provide legal opinions or official government classifications. Formal ECCN classifications can be requested from BIS, and jurisdictional questions involving the U.S. Munitions List may require DDTC review.

Why might Thermal Bros ask about my order?

We may request information about the purchaser, recipient, delivery address, end user, destination or intended use to evaluate fraud, diversion and export compliance concerns.

Does this page explain state hunting or firearm laws?

No. Export controls are separate from state hunting regulations, firearm laws, wildlife rules, airline requirements and the import laws of another country. Customers are responsible for reviewing all rules that apply to their situation.

Have a question about a Thermal Bros order?

Contact us before arranging an international shipment, freight forwarding service or trip involving thermal or night vision equipment. We can explain our store policies, but we cannot provide legal advice or guarantee that a particular export is authorized.

Disclaimer: This page is provided for general informational purposes only and does not constitute legal advice, regulatory advice, an official commodity classification, an ECCN determination, a Commodity Jurisdiction determination, an export license or authorization to export. Regulations and product classifications may change. Customers are responsible for obtaining appropriate professional advice and complying with all applicable U.S. and foreign laws, regulations, licenses, authorizations, customs requirements, carrier rules and destination-country requirements.