Export Controlled Items
Export restrictions depend on the export classification of the item and export destination. Defense articles and services under ITAR jurisdiction are enumerated on the United States Munitions List (USML) and are highly restricted. Commercial and “Dual Use” items under EAR jurisdiction are enumerated on the Commerce Control List (CCL) and have varying restrictions. The best way to obtain an export classification is from the manufacturer/producer/developer of the item. The Bureau of Industry & Security provides a list of Publicly Available Classification Information. Per federal regulation 15 CFR 758.3, it is the responsibility of the manufacturer or supplier, not the buyer to identify the export classification of items being procured. Prior to a purchase, provide the Export Control Product Classification Certification form to the manufacturer/distributor and follow the Procurement process through your Procurement Coordinator. Formal export classification requests can be submitted to government agencies; those requests must be submitted by RSIC on behalf of the university.
Deemed Exports (EAR 734.2(B)(2)(II) and ITAR 120.17) is technology released to foreign persons in the US. This is different from technology shipped from the U.S. to another country. Please see the Federal Government definition of "Deemed Exports" and watch a short video to learn more.
A Technology Control Plan (TCP) is required for research involving controlled items. TCP’s include personnel training, screening, security, and assessment stipulations. TCPs must be submitted and approved prior to undertaking controlled activities. Engage RSIC for guidance when a TCP is required.