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Martin Hegedus April 6, 2011 12:02

I'm putting together a CFD code, called Aero Troll CFD, for educational and hobbyist use. The code is compressible (i.e. subsonic, transonic, and supersonic) The code can only run on one machine and does not include chemistry or moving bodies. I live in the U.S.A. I've called the state department and they have requested that I submit a commodity jurisdiction (CJ) application to determine whether my code is covered by the U.S. Munitions List. The code and intended use was described to the state department over phone and emails. Unfortunately, and this applies to the majority of CFD codes, they can be used for the design of UAVs, Missiles, and Launch Vehicles. I've read the International Traffic in Arms Regulations and I'll admit I'm not clear on all the legalize. I'm not a lawyer. However, I figure the state department would not ask for a commodity jurisdiction application unless there was a reason. I gather it takes quite a bit of resources for them to process one.

So, I will need to do a CJ and have some questions.

Are commercial codes such as Fluent/CFX, Star-CD, or CFD++ ITAR?

Does anyone have any advice or input?


jstults August 22, 2011 10:07

I saw you linked the Analytical Methods case in one of the other threads. Seems they used dual-use CFD code for "defense services" (and they exported code that was specifically modified to model military aircraft chaff separation). That doesn't sound like what you are trying to do. IANAL, but these guys are:

Although much of the CFD software that AMI used in assisting its foreign customers was dual-use technology, the assistance became an ITAR-controlled defense service because it aided foreign military applications.
The Broad Scope of ITAR Controlled Defense Services
They make a point of saying that it would have been an ITAR controlled defense service even if the technical data they used was public domain. So the fact that they were using a sophisticated CFD code really wasn't the main issue.

On the commodity jurisdiction, that's the process if there's doubts on whether a thing is on the USML; you called with doubts, triggering the process...

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