GLOBAL TRADE COMPLIANCE AT LUMENTUM
Lumentum is committed to compliance with all applicable Global Trade Laws, including export control, sanctions and import laws of the United States and all locations where Lumentum conducts business activities. Lumentum's Global Trade Compliance organization is responsible for managing, supporting and enforcing Lumentum’s global trade compliance obligations.
Destination Controls
Lumentum products, services and technology are subject to the following destination restrictions:
- Export, reexport or transfer contrary to Global Trade Laws of any Lumentum product, service, or technology is strictly prohibited.
- Lumentum products, services, and technology are strictly prohibited from being exported, reexported or used in the following locations, along with any other location that may become subject to comprehensive sanctions:
- Cuba
- Iran
- North Korea
- Crimea
- the so-called Luhansk People’s Republic (“LNR”)
- the so-called Donetsk People’s Republic (“DNR”) - In the light of enhanced export controls and sanctions measures, some Lumentum products and services may not be available for export or reexport to Russia, Belarus, Syria or Venezuela.
- Exports or reexports to destinations that pose an elevated export control, sanctions or diversion risk for Lumentum are subject to enhanced due diligence requirements.
End-User Restrictions
Unless explicitly authorized by Lumentum and applicable government authorities, Lumentum products and technology are prohibited for export or re-export to any person or entity with whom transactions are prohibited under applicable Global Trade Laws, including but not limited to those listed on:
- the U.S. Department of Treasury's Specially Designated Nationals List
- the U.S. Department of Commerce Denied Persons List, Entity List, or Unverified List
- the U.S. Department of State's lists of Debarred Parties List
End-Use Restrictions
A license, authorization or other documentation may be required to proceed with transactions involving restricted end-uses involving Lumentum products or technology, including:
- Military end-uses that may implicate an arms embargo or similar restriction;
- Certain civil nuclear end-uses; or
- Industry-specific end-use restrictions, such as those related to certain energy and financial sectors.
All such transactions are subject to enhanced due diligence and case-by-case approval from Lumentum’s Global Trade Compliance team.
Lumentum products, services, and technology are prohibited for use with chemical or biological weapons, sensitive nuclear end-uses, or missiles, drones or space launch vehicles capable of delivering such weapons.
Classifications
Lumentum products and related technical data are classified for export under the U.S. Export Administration Regulations, administered by the U.S. Department of Commerce Bureau of Industry and Security, as well as under the Harmonized Commodity Description and Coding System (Harmonized System or HS), developed by the World Customs Organization. The most current available classifications will be available here. In the meantime, please contact GlobalTrade@lumentum.com for classification information.
The classifications are provided for guidance purposes only and are not legally binding as classifications may change without notice. It is the sole responsibility of the exporter (USPPI), re-exporter or Importer of Record (IOR) to determine and declare the appropriate classifications in accordance with applicable laws and regulations.
Our Trade Compliance Expectations
All customers, distributors, contract manufacturers, vendors and other business partners engaging with Lumentum are obliged to maintain adequate controls to ensure compliance with Global Trade Laws and prevent unauthorized export, reexport or diversion to prohibited destinations, end-users and end-uses.
If you have any questions related to Lumentum’s Global Trade Compliance Policy, please contact Lumentum’s Global Trade Compliance team at GlobalTrade@lumentum.com.
Disclaimer: This Global Trade Compliance web page is for general informational purposes only and does not constitute legal advice by Lumentum as to any particular set of facts, nor does it represent any undertaking by Lumentum to keep the user advised as to all relevant Global Trade Laws. Lumentum encourages users to seek competent legal counsel for advice. Lumentum is in no way responsible for any damages any third party may suffer as a result of using or relying upon the information provided on this page.