What are deemed exports?
In addition to actual shipment of a commodity out of the country, the export regulations also control the transfer, release or disclosure to foreign persons in the United States of technical data about controlled commodities. The deemed export regulation states that a transfer of technology or technical data to the foreign person is deemed to be an export to the home country of the foreign person. Accordingly, for all controlled commodities, a license or license exception (such as the fundamental research exemption) is required prior to the transfer of technology or technical data about the controlled commodity to foreign persons inside the U.S.
