What are export controls?
The term “export controls” means the federal laws and regulations that control the distribution to foreign nationals and foreign countries of items, services, technology, and software. In some circumstances HSPH may need to receive advance authorization from the US government to engage in such exchanges. Whether a license is required in any of these circumstances would depend on three factors: (1) the nature of the item; (2) the country of destination; and (3) the end user of the item.
Do export controls and sanctions apply to my research?
Export controls have the potential to apply to any exchange – physical or intellectual – with a foreign national or foreign country. And, if not for exclusions set out in the Export Control Regulations (EAR) and the International Traffic in Arms Regulations (ITAR) (see Exclusions you should know), many University activities would require a license to engage in them.
You can get a sense of the kinds of items, software, and technology that are regulated by perusing the Commerce Control List (Part 774, categories 0-9) for the types of microorganisms or equipment that you use. Items regulated by the State Department can be found on the United States Munitions List. (For the vast majority of research on campus at HSPH, we are not in the State Department realm.)
If you have any questions about whether your research, travel, collaborations or export of any goods and services are subject to export controls, please contact Eileen Nielsen