This policy, adopted last fall after consultations between the Commerce and State departments, could send an array of dual-use technology -- material with commercial and military applications -- to the two nations, although a top Administration export official contends that restrictions remain tight and basically unchanged.

The previous policy of denying export licenses for sales to military customers in both countries remains in place, according to a Commerce Department report sent to Congress. But the new policy says that licenses for sales to commercial customers in Syria and Iran will be considered on a case-by-case basis.

A detailed copy of the Commerce Department policy, obtained by The Times, shows that Iran and Syria now may obtain such high-tech commodities as gravity meters and magnetometers, which can be used in missile-guidance systems. They also may buy computer-controlled machine tools, which shape metal with microscopic accuracy and can be used for military purposes.

But James M. LeMunyon, deputy assistant secretary of commerce for export administration, said the policy is equivalent to the previous restrictions and that technology with military applications remains strictly controlled, even to commercial users. "There are plenty of civil end users we are saying no to," LeMunyon said. "In any case, we are not taking chances."

The policy toward Syria and Iran was first described to Congress last Aug. 28 in a letter and accompanying report from Robert A. Mosbacher, the chairman of President Bush's reelection campaign, who was then commerce secretary. The new controls were needed to replace multinational measures aimed at exports to the then Soviet Union and Eastern Bloc countries.

The report to Congress said the new controls for Syria and Iran are equivalent to the previous restrictions.

But Rep. Mel Levine (D-Santa Monica), also a member of the House Foreign Affairs Committee, called it "preposterous" to claim that there had not been a licensing change for dual-use exports to Syria and Iran. "Prior to September, there was a presumption against granting one of these licenses," he said. "Now, the presumption is gone."

After reviewing documents describing the policy, Peter D. Zimmerman, a senior fellow in arms control at the Center for Strategic and International Studies, agreed, saying: "They have precisely inverted the policy. We used to assume that anything Syria or Iran wanted was for the military. Now it appears to me we are assuming it is for innocent purposes, if they say so."

In the past, Commerce Department policy was to assume that all high-tech goods going to Syria and Iran were for military purposes; thus, almost all export licenses were generally denied. Now, requests to sell dual-use technology to commercial customers in the two countries will be decided individually without such a presumption, according to Mosbacher's report and Commerce officials.

Critics caution that it is difficult to separate commercial and military customers in Syria and Iran, much as it was in Iraq. A relaxation of export controls in the 1980s allowed $1.5 billion worth of U.S. technology to be licensed for sale to Iraq. United Nations inspectors have since found that some supposedly commercial technology was used in Iraq's massive program to develop nuclear and chemical weapons.

"This is an artificial distinction in a totalitarian society," Berman said. "The military dominates all aspects of life in Syria. There is no independent, free, private sector in that country at all."

The new controls provide greater potential access to American technology for Syria than Iran, according to the documents. For instance, while no Iranian customers may be sold navigational and direction-finding radar, requests to sell the same items to commercial customers in Syria will be considered on a case-by-case basis. The same standard applies to electronic testing equipment, marine and submarine engines and some other technology.

The August Commerce Department report acknowledged that concerns existed about keeping track of high-tech exports shipped to Iran and Syria. But it said: "The secretary has determined that the United States has the ability to enforce the controls effectively."

But ensuring that goods licensed for sale to commercial customers were used for commercial purposes proved difficult in Iraq's case. Between 1985 and 1990, the Reagan and Bush administrations approved 771 export licenses for the sale of dual-use goods to Iraq. Two government sources who have reviewed the license files said that, in one case, American agencies only checked to confirm that the goods had gone to the proper customer.

"Our capacity to know that any item which has military capabilities stays with the civilian end user is minimal, at best," Berman said. "It's just like Iraq. We're going down the same road all over again."

Commerce Department export-control officials maintain that the department and the U.S. Customs Service will focus on the Middle East enforcement efforts that were once directed at the Soviets in an effort to avoid the misuse of technology licensed as commercial.

Congress and the Administration have been debating export controls since Iraq's invasion of Kuwait in August, 1990, and the discovery that American technology assisted Iraqi President Saddam Hussein. Legislation pending in the House would tighten restrictions on the export of most dual-use goods to countries such as Iran and Syria by reinstating the "presumption of denial" standard for all cases.

Iran is spending heavily to rebuild its military and fill the power vacuum left by Iraq's defeat in the Persian Gulf War. Iranian officials have denied published reports that the country is trying to lure former Soviet scientists to work in its nuclear program.

Iran already has bought $60 million worth of American technology, such as powerful computers and navigational equipment for helicopters, according to a study released last month by the Wisconsin Project on Nuclear Arms Control, a Washington group dedicated to restricting weapons exports.

In recent years, Iran and the United States have had a troubled trade history. After the 1980 seizure of American hostages at the embassy in Tehran, Washington froze Iranian assets and imposed stringent trade restrictions; those measures were eased after the hostages were freed.

Later, during the Iran-Iraq War, the Reagan Administration imposed an embargo on arms shipments to Iran and persuaded other nations to go along.

Known as Operation Staunch, the embargo was proposed in 1984 and implemented the following year. At its height, it involved most U.S. trade with Iran. But with the conclusion of the Lebanese hostage crisis -- and Iran's reported behind-the-scenes assistance in freeing Western captives -- Washington and the West have been more receptive to Tehran's expressed desire for increased commerce.

Over the last two years, the Bush Administration had allowed the sale of limited amounts of dual-use technology to Iran for commercial purposes.

Syria, meantime, has resisted international efforts to inspect its nuclear facilities, arguing that it will agree to such examinations only if Israel allows similar inspections. However, Syria agreed Monday to negotiate an accord with the International Atomic Energy Agency in Vienna that would allow inspectors into the country.

Frantz is a Times staff writer and Waas is a special correspondent.