Trade Compliance Information Sheet

This Trade Compliance Information Sheet is intended to make you are aware of important trade and export compliance regulations. The information is not comprehensive or exhaustive, and is provided primarily in relation to the export and sale of U.S. technologies and products under the U.S. Dept. of Commerce’s Export Administration Regulations. In addition to U.S. export regulations, the products/services may be subject to EU, EU member state or other state export regulations. To insure you understand the export regulations of any specific country, please consult with the appropriate national or local trade and export compliance agency.  It is your and not Ingram Micro’s responsibility to ensure that your export and resale transactions do not violate the export control regulations enacted by U.S., the EU, or any specific country, and that you have obtained required export authorizations/licenses before you proceed with your export, import and resale transaction. 

Product Classification

-      The level of controls applied to a transaction is determined by the government-designated classification of the                                 product/service in combination with the country of destination. Based on the product/service classification, certain                         technologies products may require prior export license approval as defined within the scope of the applicable regulations.             These types of products/services include but are not limited to:

-      Hardware, software and technology products with high levels of encryption functionality.

-      Certain network infrastructure products such as high-end routers or switches designed for high volume communications.

-      Products exported to foreign government end-users.

-      Certain network infrastructure products exported to foreign telecommunications companies and Internet Service Providers                  (ISP’s).

-      Products/services determined to be of dual use (civil and military use) 

Customer Compliance Screening – Know Your Customer

Products/services purchased from Ingram Micro must not be sold to any person, entity or business listed on any of the denial lists published by government authorities including the U.S., E.U. and local government.  It is illegal for a U.S. company or its foreign subsidiaries to conduct export or transact business with a company or individual listed on the U.S. Government's Table of Denial Orders, Entity List, Specially Designated Nationals List or the Debarred List.

It is your responsibility to know and screen your customer to ensure that you do not deliver products or services to restricted, denied or sanctioned parties, and you shall not rely upon any assessment or decision made by Ingram Micro with respect to any customer restrictions. 

Destination Country Screening

You may not, without a valid license, export or re-export products or services to any embargoed countries, which currently are identified as Cuba, Iran, North Korea, Sudan, Syria, and the Crimea Region of Ukraine.  For information concerning export licenses you should contact the U.S. Embassy or Consulate or the competent E.U. or national authorities.

Non-Proliferation of Weapons of Mass Destruction (WMD)

Non-Proliferation Screening is based on detailed regulations covering product/service end-use and end-user activities.  Non-Proliferation Screening has been enacted to insure that resale transactions do not involve:

-      Prohibited nuclear end-uses and/or end-users without proper licensing authority issued by the U.S. Government, appropriate        E.U. governing body, or local government.

-       Prohibited missile end-uses and/or end-users without proper licensing authority issued by the U.S. Government, appropriate         E.U. governing body, or local government.

-      Prohibited chemical and biological weapon end-uses and/or end-users without proper licensing authority issued by the U.S.          Government, appropriate E.U. governing body, or local government.

You may not, without a valid license, knowingly resell any product/service involved in proliferation activities.  Although most of the products/services that Ingram Micro offers for resale can be legally resold and exported, it is illegal to make products or services available to anyone engaged in the proliferation of nuclear, chemical or biological weapons, or in missile technology development.

High Risk for Diversion Screening Guidance

Diversion Risk screening is designed to avoid a violation of any part of the applicable governing trade and export regulations. You are prohibited from proceeding with a resale, export, re-export or other transfer of products/services if you have knowledge that a violation of the export control regulations may or is about to occur, or has actually occurred in connection with any disposition of the products/services. You may not resell, export, re-export or transfer any products/services if you have knowledge that your customer (or any other party) will export, re-export or otherwise transfer products/services without having obtained the proper license or authorization. It is illegal to knowingly make products/services available to any persons or companies who intend to divert such products/services to unauthorized or restricted destinations, end-users or end uses.

U.S. Government Country Group D List

The Country Group D list identifies countries where the U.S. has national security or proliferation concerns based on activities including but not limited to nuclear proliferation, missile technology development, and chemical and biological weapons development.  Based on these concerns, the U.S. Government restricts exports or re-exports that would make a material contribution to any of these activities in Group D Countries.  Depending on the Export Control Classification Number (ECCN) assigned to the product/service, certain technology, computer and telecommunication products/services may require a formal export license approval from the Bureau of Industry and Security.   The Country Group D list is available in Supplement No. 1 to Part 740 of the Export Administration Regulations.  For further information contact the U.S. Embassy or Consulate.

The Country D list consists of the following countries: 

Manufacturer Restrictions

Certain products/services offered for sale by Ingram Micro are subject to specific manufacturer restrictions with respect to which countries and to which customers the products/services can be sold by Ingram Micro. Although the products/services can generally be sold freely within the European Economic Area (EEA) and Switzerland, most products/services are subject to restrictions with respect to resale outside these countries. If you intend to resell any products/services acquired from Ingram Micro outside the EEA or Switzerland (irrespective of any government export regulations), please consult with your Ingram Micro account manager for any manufacturer directed resale restrictions. Violation of manufacturer restrictions may result in Ingram Micro being prevented from conducting further sales to you of the manufacturer’s products/services. It is your responsibility to know and meet any manufacturer directed restrictions.