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Dual Use Changes | 02 Dec 2014

Dual Use Changes

Table of Contents
General Information
Appendix A - F.A.Q.
Appendix B - How do I know if I have controlled product or not?
Appendix C - What is the functional compatibility of new and old products?
Appendix D - Functionality Decision Flow Chart

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Appendix E - Product Inventory Flow Chart

Table of Contents

General Information
Kollmorgen is updating the AKD and Servostar drive products firmware in order to comply with the
recently revised US & EU export regulations (EU Dual Use Regulation 428/2009 & U.S. Dual-use
regulation EAR Category 3 under ECCN3A225). This revision will reduce the open loop frequency limit to
599 Hz, without this change our products would become dual use goods in both the US and EU and may
require Kollmorgen and/or you to obtain export licenses when exporting these products. While most
customers will not be affected by the functional change or product compatibility changes caused by the
update, the frequency limit may eliminate the need to obtain an export license however you should
consult your export compliance administrator.

These product updates will occur in product shipped after Dec. 15th, 2014.

Please see Appendix A for references to the US and EU Amended Export Classifications for these
Products.

Products affected:

Kollmorgen AKD servo drive – all models (model numbers starting with: AKD-B, AKD-P, AKD-T,
AKD-N, AKD-M)

Kollmorgen Servostar drive - (part numbers starting with: S7xx, S3xx, S6xx, S4xx)

*See product label schemes in Appendix B to identify affected product

Customers that are affected will have several options available to ensure compliance with export
regulations and also to maintain product compatibility. See Appendices C and D for an explanation of
possible actions.

Some Kollmorgen legacy products will also be affected by the dual-use laws, but will not be updated.
Please check Appendix A, if older products you are using will fall under the export control.

If you do not use the above products, you are not affected in any way. For previously purchased products,
the new export regulations do not require changes if products are integrated into higher level assemblies
prior to export. If you have AKD or Servostar product in inventory, you may be required to comply with the
new regulations, but only if you are exporting product without installing it into a top level assembly before
export. This includes product sold as “spare parts” that may be shipped to customers. See Appendix E
“Product Inventory Flow Chart” to understand your options and actions if you fall into this case. This letter
is intended to generally inform you on the change in the export regulations and the steps that Kollmorgen
has taken in response to the regulation change. Accordingly, you are encouraged to consult your export
compliance professional with any questions and to determine how these regulations may impact your
business in the future.

Appendix A - F.A.Q.
Q: What regulation(s) are changing?

A: The following regulations:

EU Dual-use Regulation 428/2009

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U.S. Dual-use regulation EAR Category 3 under ECCN3A225

With the AKD and Servostar drives’ capability to potentially commutate an AC induction (open loop
operation) over 600 Hz, we have chosen to limit the commutation frequency in all future product to
599Hz. This change will exempt the products from the classification and allow them to remain non-
controlled product. Most industrial automation products fall under this general classification.

Q: Why do regulations apply to these products at > 600Hz commutation?

A: The regulations are intended to prevent certain individuals from obtaining technologies that can be
used to build high speed centrifuges, which are an enabling technology for the enrichment of Uranium.
Please consult your export office for certain countries that may require an export license.

Q: Is the model number of the product changing?

A: No. The model number of the product is not changing.

Q: Is the firmware version changing?

A: Yes, in the AKD Product Family the new version of firmware shipping from Kollmorgen will be
V01_13_xx_xxx (or later) and will be non-controlled items in the context of these regulations.

In the Servostar product family the firmware versions will be changed according to the following table:

Fw version State Comment

Export controlled (Dual
x.xx (e.g. 9.50)
use) Old Fw shipped before Dec. 15th

x.xx_ND0 (e.g. Non controlled (non Fw with limited output frequency in

9.50_ND0) Dual use) sensorless mode,
Fw with non limited output frequency,
x.xx_ND1 (e.g. Export controlled (Dual
dedicated to customers which need this
9.50_ND1) use)
functionality

Q: How do I determine that I need a license if I decide that I want to export old product that I have
in inventory?

U.S.: http://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear

In any other country: Other regulations and rules may exist. Contact your export office for more
information.

Q: Can I get product updated by Kollmorgen?

A: Yes, product can be returned to Kollmorgen for the updates free of charge. However, freight costs will
not be covered by Kollmorgen. Follow the RMA process to return the product. It will be upgraded and
returned as uncontrolled product.

Q: Can I convert these products from “Controlled” to “Not Controlled” in the field (i.e. can I do it
myself)?

A: No, the product must be returned to Kollmorgen if this update is necessary. See “Product Inventory
Flowchart” for guidance. Follow the RMA process to return the product. It will be upgraded and returned
as uncontrolled product.

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Q: Are any other products affected?

A: These Kollmorgen HF-Drives are affected. These are legacy obsolete products, which are very rarely
sold anymore.

ACO 5000, K 4000, VHF 1400

These will be listed 3A225. We will not re-engineer changes to create a compliant dual-use product.

Appendix B - How do I know if I have controlled product or not?

Label from AKD Product Family

Label from Servostar

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EU Wiki page - http://wiki-kollmorgen.eu/wiki/tiki-index.php?page=Export+Classification

Appendix C - What is the functional compatibility of new and old products?

AKD Functional Compatibility Matrix

Physical Product Firmware Version Compatibility Notes

New product is compatible with the new

firmware V01_13_xx_xxx or later, or the
"compliance updated" versions V01_11_00_011
new product new firmware compatible
& V01_12_00_003; which are being offered to
help customers concerned with change control
and want to use prior releases

New product is not compatible with older

firmware due to the new regulations. Customers
new product old firmware not compatible must upgrade to new firmware, which is
V1_13_xx_xxx or one of the patch versions of
older firmware which has been made compliant.

When the new firmware is downloaded, the

produced is upgraded to the newly compliant
old product new firmware compatible state. The product can no longer be used with
older firmware. It is now locked to compliant
versions of firmware only.

Old Firmware will no longer be distributed by

old product old firmware compatible Kollmorgen, but customers can continue to use
old firmware if they have it.

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Servostar Functional Compatibility Matrix:

Export
Physical Old New
No license Display Display
Product Firmware Firmware
needed

Compatible,
Old Compatible,
1 maybe No freq. 5.80 5.80_ND0
product Freq limit
Limit

New Not Compatible,

2 No ----- 5.80_ND0
product compatible Freq. limit

Compatible, Compatible,
Old
3 maybe No freq. 5.80 5.80_ND1
product
Limit No freq. limit

New Not Compatible,

4 maybe ----- 5.80_ND1
product compatible No freq. limit

1. This refers to drives, which have been shipped before 12/15/2014.

2. Refers to standard drives, shipped after 12/15/2014 with limited output frequency.
3. Refers to new drives with export license, which can be used with old firmware. This version will only
be available on request.
4. Refers to new drives with export license.

Appendix D - Functionality Decision Flow Chart

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Appendix E - Product Inventory Flow Chart

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Q: Will an export license be required to return product from outside to Kollmorgen?

A: No.

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About this Article

Katie Veenhuis
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Product(s)
AKD AKD BASIC S200 S300 S400 S600 S700
Subject
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technical bulletin compliance dual-use regulations ECCN3A225 export

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