Export Control and International Travel
When traveling abroad there are three basic questions that University faculty, staff and students need to consider when determining if export controls apply to their travel:
Where are you going?
In general, travel to most countries is not a problem. Tighter export controls are in effect for countries that are comprehensively sanctioned or have restrictions on trade enforced by various departments of the U.S. government.
The following, most comprehensively-sanctioned countries will require advance planning and coordination with OSPRS:
- North Korea
Contact us as soon as you anticipate travel to one of these countries.
When traveling abroad, it is always a good idea to contact the appropriate U.S. Embassy or Consulate before you depart. To register your travel plans with an embassy and receive helpful safety and emergency information related to your destination, visit the Department of State's Smart Traveler Enrollment Program or the U.S. Embassies and Consular Offices website for more information.
What are you taking with you?
Items and Equipment
When taking items abroad (including scientific equipment, laptops, encryption software, cell phones, tablets, flash drives, cameras and GPS units), you need to verify that the items are not export restricted based on your travel destination(s).
When transiting between countries you may be asked to provide an Export Control Classification Number (ECCN) for each item you take.
Please refer to the chart below for the ECCNs for equipment most commonly taken abroad. If you are planning to take equipment that is not listed in the chart below, please contact OSPRS to obtain the ECCNs for your specific item(s).
Most commercially available basic software (such as Microsoft Office) is EAR99, and can be exported either individually or on your device without a license.
However, proprietary software, software that includes encryption and/or other complex software may require an export license and should be reviewed by the Export Compliance Office. Please contact OSPRS if your device includes any of the above software.
ECCNs for Common Travel Items*
*Do NOT use this chart for travel to Cuba, Iran, North Korea, Sudan or Syria
|Dell Laptop (no encryption)||4A994||No Licensed Required (NLR)|
|Mac Laptop||5A992||No Licensed Required (NLR)|
|iPhones & iPads||5A992||No Licensed Required (NLR)|
|Jump/Flash Drive (most)||3A991||No Licensed Required (NLR)|
|Android Cell Phone/Tablets||5A992||No Licensed Required (NLR)|
|Garmin GPS||7A994||No Licensed Required (NLR)|
|GoPro Camera||EAR99||No Licensed Required (NLR)|
If you are traveling with items to one of the "comprehensively sanctioned" countries of Cuba, Iran, North Korea, Syria and Sudan, or providing access to your items to a citizen of one of those countries, an export license will most likely be required.
It is highly recommended that you register any items/equipment that you will be taking with you with U.S. Customs and Protection (CBP). Registration allows you to prove that you had the items before you left the U.S. and all CBP registered items will be allowed to return to the US duty-free.
Research Data and Information
You are free to take and openly discuss any data or information that is published, in the public domain, is normally taught as part of a catalog course at CCU or that resulted from fundamental research. However, you cannot take or share data or information that is in any way export-restricted, such as information about export-controlled technologies, proprietary information or the results of a project not protected under the Fundamental Research Exclusion.
Sharing these types of information may constitute an unauthorized export. All controlled or restricted data and information should be completely removed from laptops, phones, PDAs or other portable storage devices (e.g., flash drives) before you leave the U.S.
What will you be doing and who will you be interacting with?
It is important to ensure that you do not accidentally export restricted information or provide any type of assistance or benefit to a sanctioned or blocked entity. The following are a few things to keep in mind as you plan your travel activities:
When presenting data/information in an international setting (including in the U.S. where the audience may include foreign nationals), you need to ensure that you limit your presentation to only information or data that is published, publicly available or that qualifies as fundamental research.
Be careful not to include or discuss any proprietary, unpublished or export-restricted data or information as that may constitute an unauthorized export.
Interactions with Foreign Colleagues
As noted above, you are free to openly discuss any published or publicly available information or information generated as the result of fundamental research, as long as the recipient is not a sanctioned or specially designated entity.
It is important to remember that while the results/information from fundamental research are not subject to export controls and can be shared without a license, any items, technology or software generated under that fundamental research would be subject to export controls and may require an export license.
Any University research activity done outside the U.S. may not qualify for the Fundamental Research Exclusion. Before disclosing or sharing information or data resulting from international field work it is important to ensure that the information is not export restricted.
In addition, please contact OSPRS as soon as possible if any of the following factors are involved with your research:
- Taking equipment other than items listed in the ECCN chart above;
- Providing payments of any kind to a foreign person, university or organization;
- Purchasing or obtaining items or materials from international sources;
- Planning to bring back samples;
- Sending equipment, materials or information from the U.S. to a foreign destination; or
- Potential or existing non-disclosure agreements or restrictions on the publication of research results.
Provision of Financial Assistance
To ensure compliance with OFAC regulations prohibiting the University from providing material or financial assistance to any blocked or sanctioned individual or entity, any University activity that involves payment to a non-U.S. person, business or organization (e.g., international subcontracts, purchase of items from international vendors or payments to research participants) must be verified against all appropriate sanctioned party and entity lists.
Compliance with export control regulations is an individual responsibility. To help ensure smooth international travel and compliance, contact OSPRS at ext. 2978 if you have questions or concerns about export controls as they may apply to your travel plans.
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