"It's Just a Sensor"—Until It Isn't

A customer just asked for your export classification documentation. You don't have any. Here's why "we're commercial, not military" isn't the answer they're looking for.

You just got an email from a potential customer. Big deal. Government-adjacent end user. They want to move forward.

But first, they need your export classification documentation.

You don't have any.

Your product is commercial. You sell to construction companies, environmental consultants, industrial clients. You've shipped internationally. Nobody asked for classification documents before.

Now you're Googling "Wassenaar Arrangement" and "Category 6 controls" and finding technical parameters that look like your own spec sheet.

You have two problems. You don't know if your product is controlled. And you can't prove it either way.

This applies to sensors, detection equipment, measurement devices, imaging systems—any hardware where technical specifications might cross control thresholds.

The Fear Nobody Says Out Loud

Let's name it: you're worried you've been doing this wrong.

Maybe you've shipped for years with "NLR" on the paperwork. Maybe you self-classified based on a quick read of the control list. Maybe you copied what a competitor put on their documentation.

Now someone is asking for proof.

Here's the first thing you need to hear: controlled doesn't mean prohibited.

Most controlled products ship legally every day. Companies shipping them have classification determinations, appropriate licenses, and documented end-user verification. They're not doing anything special—they just know what they're shipping and can prove it.

The problem isn't being controlled. The problem is not knowing—and finding out at the wrong moment.

"Regulators see capability, not intent. Your product might be sold to construction companies. If its specifications cross certain thresholds, it's controlled—regardless of marketing."

What People Do Instead

"We self-classified. We're fine."

Export control lists are technical and nuanced. Misread a threshold, overlook a catch-all provision, miss a parameter—you have incorrect classification. "We thought we were fine" isn't defensible when customs challenges or an auditor asks.

Self-classification works for products clearly below thresholds shipping to low-risk destinations. The danger is borderline products, sensitive destinations, or government end-users—where "we think we're fine" becomes exposure.

"We put NLR on everything."

No License Required is a determination, not a default. If your product requires a license and you've been marking it NLR, you have an export violation for every shipment.

"Nobody ever asked before."

Until they do. A sophisticated customer. A government contract. A customs hold. An audit. The moment someone asks for documentation you don't have, your history becomes liability.

The Double Classification Trap

Your product may need two classifications.

Export control (dual-use): Is it on the Wassenaar control list? Does it require a license based on technical parameters and destination?

Dangerous goods (transport): Does it contain lithium batteries? Radioactive sources? Pressure vessels?

A radiation detector often hits both—Category 6 dual-use for detection capabilities, Class 7 DG for radioactive calibration sources. Different regulations. Different timelines. Both must be satisfied.

One more factor: US-origin content. If your product contains American components above de minimis thresholds, US export controls may apply regardless of Swiss classification. This catches many companies using US semiconductors or software.

The Cost of Getting It Wrong

The Exposure:

Swiss sensor company. Shipped to Asia for three years. Self-classified as uncontrolled.

Customer requested formal documentation for a government tender. They couldn't provide it. Lost the deal.

Worse: formal classification revealed they'd been shipping controlled goods without authorization. Three years of shipments. Retroactive compliance review. Six months to remediate. €40K+ in costs.

The Asset:

Different company. Similar product. Got formal classification before first international shipment.

First shipment: effort required. Tenth shipment: copy, paste, ship. Confident delivery quotes. No customs holds. No documentation requests they can't answer.

Classification isn't cost per shipment. It's investment that pays across every future shipment.

Key Takeaways

Commercial ≠ uncontrolled. Regulators assess capability, not marketing.

Controlled ≠ prohibited. Most controlled products ship fine. The issue is knowing and documenting.

Self-classification has limits. Fine for clearly-below-threshold products. Dangerous for borderline cases.

Two classifications may apply. Export control AND dangerous goods. Plus US-origin content.

Classification is reusable. First shipment is effort. Tenth is copy-paste.

What To Do Now

Customer just asked for documentation you don't have?

Don't guess. Don't stall. We turn around classification determinations in 1-2 weeks. Typically €2,500-5,000 depending on complexity—a fraction of the cost of getting it wrong.

Been shipping without formal classification?

You have exposure. The question is how much. We assess your product against control lists and tell you where you stand—before someone else asks.

Launching a new product?

Build classification into go-to-market. Know before you ship. First demo shouldn't be when you discover you need a license.

hello@flowspex.ch

FlowSpex classifies hardware against Wassenaar control lists and DG regulations. We produce documentation that meets customer, customs, and auditor requirements. Technical language in, compliance confidence out.

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