Export Compliance

De Jaeger Automation BV has reviewed ProSuite against the principal export control regimes. The classifications below are provided for customer information and may be updated.

2.1 European Union — Dual-Use Regulation (EU) 2021/821

The general catch-all controls under Regulation (EU) 2021/821 may nevertheless apply where ProSuite is or may be intended for an end-use that would otherwise require authorisation under that regulation. The relevant prohibited end-uses are listed in section 4 below.

ProSuite is not a defense-related product within the meaning of the EU Common Military List and is not subject to controls under that list.

2.2 United States — Export Administration Regulations (EAR)

ProSuite is developed outside the United States and does not, to the best of De Jaeger Automation BV’s knowledge, incorporate controlled US-origin software or technology above the de minimis level under 15 CFR §734.4. Where ProSuite is supplied from the United States or to a US person, the following classification applies:

ProSuite is industrial work-instruction and process-control software whose cryptographic functionality is limited to standard transport security and authentication. It does not meet the criteria of any controlled Export Control Classification Number (ECCN) on the Commerce Control List and is accordingly classified as EAR99. 

ProSuite is not a defense article on the United States Munitions List (USML) and is not subject to the International Traffic in Arms Regulations (ITAR) administered by the US Department of State.

2.3 United Kingdom

ProSuite is not listed under the UK Strategic Export Control Lists. UK catch-all and trade-sanctions controls apply on the same basis as in the EU.

2.4 Asia — country-specific regimes

ProSuite will not be supplied, made available or supported, directly or indirectly, in or to:

Comprehensively sanctioned territories

Cuba, Iran, North Korea (DPRK), Syria, and the non-government-controlled territories of Ukraine (currently Crimea, the so-called Donetsk and Luhansk People’s Republics, and the Kherson and Zaporizhzhia oblasts).

Russia & Belarus

Supply to Russia and Belarus is restricted under Regulation (EU) 833/2014 and Regulation (EU) 765/2006 (as amended) and equivalent US, UK and allied measures. ProSuite is not supplied to customers in Russia or Belarus except where expressly authorised by the competent authority.

ProSuite will likewise not be supplied to any party listed on the EU Consolidated Financial Sanctions List, the US OFAC SDN/SSI lists, the US Commerce Entity List, the UK OFSI Consolidated List, the UN Consolidated Sanctions List, or any equivalent national list applicable to the supply.

Regardless of destination, ProSuite must not be used and customers must not permit any third party to use ProSuite in connection with:

• the development, production or use of chemical, biological, nuclear or radiological weapons, or of missiles capable of delivering such weapons;
• any end-use prohibited under the export control or sanctions laws applicable to the supply or to the customer;
• any attempt to circumvent applicable sanctions or export control measures.

These restrictions reflect the catch-all controls in force in the European Union, the United Kingdom, the United States and the Asian jurisdictions referenced in section 2. They are stated here because they apply to all commercial software supplied across borders, and not because of any controlled characteristic of ProSuite itself.

By accepting ProSuite, the customer represents, warrants and undertakes that it will:

1. comply with all export control, sanctions, customs and trade laws applicable to it and to the supply;
2. not export, re-export, transfer or make ProSuite available, directly or indirectly, in violation of those laws;
3. screen its own customers, users, partners and end-users against applicable restricted-party lists before granting them access to ProSuite;
4. not use ProSuite for any prohibited end-use described in section 4;
5. obtain any export, re-export, transfer, brokering or import authorisation required from the competent authority of the country of supply, the country of receipt, and any country of transit; and
6. notify De Jaeger Automation BV in writing without delay of any actual or suspected breach of this page or of any applicable export control or sanctions law in connection with ProSuite.

The classifications stated in section 2 apply to direct supply by De Jaeger Automation BV. Where a customer re-exports, transfers (including intra-group), sublicenses or otherwise makes ProSuite available across a border, the customer is responsible for determining and complying with the export control rules applicable to that transaction, including for cloud access by users located outside the country of original supply.

For SaaS deployments, the customer is responsible for ensuring that user accounts are not granted to, and ProSuite is not accessed from, any sanctioned territory or restricted party.

De Jaeger Automation BV may, on reasonable notice, request information from the customer reasonably necessary to verify compliance with this page, including end-user, end-use, country of installation, and the identity of personnel accessing ProSuite. The customer agrees to cooperate in good faith with any inquiry, audit or investigation by a competent export-control or sanctions authority.

De Jaeger Automation BV may update this page at any time to reflect changes in applicable law, in ProSuite, or in its own assessment. The version in force on the date of supply governs the supply. Customers should review this page periodically.

Export Compliance: De Jaeger Automation BV

Hendrik Consciencelaan 79

B-9950, Lievegem, Belgium

Email: export@prosuite.eu

Phone: [+32 9 378 49 89]