For those engaged in exporting kits from outside the US, this case is a timely reminder that you need to perform the de minimis calculation carefully and in accordance to with the BIS guidance.

In a February 2026 settlement, Teledyne FLIR LLC agreed to pay $1 million in civil penalties for 19 alleged Export Administration Regulations (EAR) violations involving thermal camera exports and de minimis miscalculations. BIS alleged that for camera cores exported with lenses, FLIR used the value of cores without lenses, thus undervaluing the US-origin content.
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Facts: FLIR US exported "camera kits" and "camera cores" to FLIR Sweden. Instead of calculating the de minimis content based on the total value of the discrete items that the kits will be assembled into, FLIR Sweden only used the values of the controlled components within the "camera kits" or "camera cores" in the calculations. This resulted in under-valuing the controlled US-origin contents when FLIR Sweden subsequently performed its de minimis calculations for its foreign-made products.

BIS also alleged that in 2018, FLIR engaged in evasion by structuring a "market collaboration fee" arrangement with a Chinese drone manufacturer (DJI) specifically to keep US-controlled content below the 25% de minimis threshold for the "Zenmuse XT2" project.
Separately, FLIR was also accused of shipping to an entity with "address only" entries ("Address 04") on the Entity List where the company appeared as part of a shell company structure. These exports required a license (under EAR §744.16) but were allegedly made without authorization.

The key takeaways are broadly twofold: (i) exporters cannot perform de minimis calculations on an individual component basis, but rather on the entire discrete product at the time of export, and (ii) companies must also ensure pricing structures with foreign partners genuinely reflect fair market value and are not seen to circumvent regulatory thresholds.

It is also essential that companies do not rely solely on name-based screening, but also ensure there is no match to "Address only" entries on the Entity List.