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FrozenGate by Avery

Survival Laser Offers First Class International Shipping






Just put it in the cart and click checkout. You will see the shipping options and prices before you pay. :)

BTW First Class international now has limited tracking.
 
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Photonz said:
Shipping is $10-14 most likely $10. Unaware of other thread:p
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Photonz, that's helpful of you and great to know SL's actual shipping charges too. If not for mustangman1, I wouldn't have been aware of Survival Lasers' new provision to cater to orders from international customers. :beer:

Btw : Apart from leaving out the invoice, wonder if SL's packages do avoid any mention of their company name (because of the word 'laser') or any reference to it in the return/sender's address and customs declaration label? :thinking:
 
OrionBLF said:
Photonz, that's helpful of you and great to know SL's actual shipping charges too. If not for mustangman1, I wouldn't have been aware of Survival Lasers' new provision to cater to orders from international customers. :beer:

Btw : Apart from leaving out the invoice, wonder if SL's packages do avoid any mention of their company name (because of the word 'laser') or any reference to it in the return/sender's address and customs declaration label? :thinking:
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Sure:), and the package my driver came in does mention their company name on the label.
 
Is there a way to bypass the restriction against shipping to US customers? It's rather irritating that a US company is unable to ship certain items to US residents. Generally speaking, one expects export restrictions to apply to our enemies, not the other way around.

Yes, I know about 21 CFR 1040.10 (b) (19) and (21). (b) (19) defines "laser". (b) (21) defines "laser product" and also states that "a laser or laser system that is intended for use as a component of an electronic product shall itself be considered a laser product."

Ok, a laser diode is therefore a laser product. Got it.

Sam, author of the Laser FAQ cites (b) (21) as argument that it's illegal to sell bare laser diodes as parts. But (b) (21) doesn't give us the whole picture. Looking at 21 CFR 1040.10, here is what I see:

First, we have 1040.10 (a) (2) and (3). (a) (2) states that laser products are not subject to the restrictions in 1040.10 and 1040.11, provided that the laser product is sold as a component only, and not as part of a complete laser system. It also requires that relevant safety papers are included in the sale. (a) (3) seems to set record-keeping requirements for "manufacturers" who sell exempt laser products.

Thus, a laser diode labelled and sold as a component only would seem to be exempt from restrictions per (a) (2) (ii). Whoever sells it to you is required to keep a record of the sale and make that info available to the feds per (a) (3).

But what about (a) (2) (iii), which makes reference to (c) (2), which deals with "removable laser systems"? (c) (2) says that any "laser system" used in a laser product which can be removed from said laser product and then made to lase without modification is considered a "removable laser system" that is subject to the restrictions in 1040.10 in general.

So maybe a diode is subject to restrictions after all? I don't believe so, because (b) (23) clearly defines a "laser system" as including a laser product plus a laser energy source; and (c) (2) clearly deals only with "laser systems". A bare diode lacks an energy source, thus it is not a laser system per (b) (23). This is also true if the diode is pre-pressed into a module. Because a diode is not a laser system, (c) (2) cannot apply to it.

Thus, it would seem that a laser diode is indeed exempt from restrictions, provided the diode is sold as a component only, that the required warnings/advisory papers are included, and that the seller keeps records as required.

Part (b) (20) seems to warrant a closer look. Per (b) (20) a driver board appears to be a "laser energy source". (However, batteries, AC supplies, and the like are not.) So, a diode plus driver is a laser system per (b) (23). However, it is not a removable laser system per (c) (2) because the diode/driver combo was never incorporated into any other laser product. Thus, it appears that one can sell a diode/driver combo as an exempt laser product in the same manner as a bare diode.

With all that in mind, why does Survival Laser refuse to sell diodes to US customers? Is there more to it than that? Did their attorneys advise them to "just play it safe and don't risk it", despite 1040.10 providing ample exemptions to allow such sales?

If there is an articulable reason for their refusal to sell diodes to US customers, it would be nice if that explanation were provided on the US store site. It would still be irritating, but at least it would be understandable at that point.

But, and while I'm definitely NOT an attorney, it would seem that Survival Lasers should be able to sell diodes to US customers, provided they follow 21 CFR 1040.10 (a). But, we just saw how that section interacts with others. The law is rather convoluted.

That is what I'm understanding at this point, can anyone elaborate further, or call BS on any errors I made in interpreting that law?
 
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^^^ Yes the law is rather convoluted. That gives rise to a variety of interpretations, especially in favor of the FDA. I share your frustration and irritation with the situation.

If we were to sell diodes to US customers, the FDA could take the position that all our products are "laser products" and therefore regulated.

I have spent enough of my time and money in this fight. If someone else would like to take them on, be my guest. ;)
 
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