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authority concerns on trade issues about US EAR

We are concerned about the authority of ROS as recently arised trade issues between US and the rest of the world (especially China). We are looking forward to get your official answers for the questions below:

  1. Is the ROS project subject to U.S. Export Administration Regulations (EAR) and classified under ECCN 0D521? Or such AI software is subject to EAR, but not classified under ECCN 0D521?
  2. Is U…S. Bureau of Industry and Security license required for exporting this project to China?

Just to clarify this is the ECCN mentioned. The TL;DR is that this is a new regulation imposing ITAR restrictions on software related to the automated processing of geospatial data using deep learning.

I am in a unique position in that I used to work on this type of software at a previous employer. I do not believe this law applies or is intended for the ROS community. It seems to be narrowly scoped to be applied to deep learning for satellite geospatial imagery. Having said that, I am not a attorney, and this is just my personal opinion. If you are concerned about this issue you should consult with an attorney.

Could this be something OR could make sure of for at least something like ros_core and the other official variants (REP-142, REP-150)?

That would help avoid confusion and uncertainty (and perhaps a lot of work for lawyers, but :man_shrugging: :slightly_smiling_face:).

1. Provides a graphical user interface that enables the user to identify objects ( *e.g.* , vehicles, houses, etc.) from within geospatial imagery and point clouds in order to extract positive and negative samples of an object of interest;
2. Reduces pixel variation by performing scale, color, and rotational normalization on the positive samples;
3. Trains a Deep Convolutional Neural Network to detect the object of interest from the positive and negative samples; and
4. Identifies objects in geospatial imagery using the trained Deep Convolutional Neural Network by matching the rotational pattern from the positive samples with the rotational pattern of objects in the geospatial imagery

@gavanderhoorn Where in ROS core do you see these specific tasks? The order it is very narrowly scoped to impact a specific set of vendors that provide products for that particular workflow.

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In my experience it doesn’t really matter what I believe or how I see things, especially in contexts that are sensitive to these kinds of topics (ie larger corporations looking to make use of externally developed components), as I’m not a lawyer.

Seeing as much (most?) of ros_core and related packages is essentially under OR’s control, it would be beneficial to have a statement that says something like you just wrote.

True enough, but you can’t have a lawyer check every ECCN. What makes this ECCN special? Given the part that @Katherine_Scott quoted, I don’t see how anything in ros_core (or even desktop_full) could possibly fall under the scope.

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Not every one, no. But this one has gotten a bit of attention.

And the questions don’t come from engineers who know what is going on or what they’re using.

Again, it doesn’t matter what I (or you) see or imagine.

I’ll withdraw the request though: let’s see what happens and how many questions we get about this (both on and off-line).

Ok, that partly answers my question “what makes this ECCN special”: you seem to have gotten questions before about this, whereas for me this thread is the first I heard of it. If this specific ECCN is something that many (potential) ROS users care about, we should consider an official statement. I think it hasn’t gotten to that point yet, or have I missed something completely? (honest question)

I think the point where we agree is that if you have doubts whether a given legal document applies or not, you should hire a lawyer instead of doing your own guesswork. I think the point where we disagree is that you seem to have those doubts, whereas I don’t.

I could of course provide absurd examples of ECCNs where we would both agree that they have nothing to do with ROS or even with software in general, so what you and me “see or imagine” clearly does matter to an extent.

The ol’ shuffling lawyers fees to the other folks trick, very clever :wink:.

But more seriously, I think this starts a bad precedence making it OR’s problem to tell people if they are allowed to use [ROS and related stuff] according to [some treaty, international restriction, etc]. That would be a never ending battle at great legal expense to OR for a company’s individual concerns.

And as a personal, non-legal opinion, that restriction has nothing to do with their field of robotics or ROS. I don’t think it should be a concern unless you’re using ROS for a geospatial application, but in that case its still not ROS’s fault that you’re using that technology in that way.

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Are there other ECCNs that may be relevant to the core parts of ROS? Surely some UAVs and components must be covered? Especially the large, long-duration stuff.

Given how long these documents are, it seems unlikely there is only one ECCN relevant to mobile robotics.