Export Control for Universities
Within the global environment of research, universities can be impacted by the legal definition of an export:
An export is “Any item that is sent from the United States to a foreign destination"
Disclosure of certain items/information to certain non-U.S. persons is also considered an export
"Items" include, "commodities, software or technology, such as clothing, building materials, circuit boards, automotive parts, blueprints, design plans, retail software packages and technical information.” according to the U.S. Department of Commerce.
There is a "fundamental research" exception available to university researchers (PIs).
However, both the U.S. Department of Commerce and the U.S. State Department define a number of research circumstances that are not eligible for this exception.
Work not considered "fundamental research" requires a license from the federal government prior to the release of “items” - data, equipment, design, process or material specifications - to non-U.S. persons.
Export Control Regulations apply to:
- The transfer, or “export” of specified items or information to people or entities outside the United States;
- The disclosure of certain information to certain foreign nationals inside the United States (often called a “deemed export”);
- The training or offering of services involving controlled equipment or information to foreign nationals; and
- Transactions with, or providing services to, certain foreign countries or individuals who are on the denied entities/persons lists.
Activities impacted by Export Control at ISU:
1. Foreign Travel Export Control Review Process - Any "Out of Country" travel by ISU faculty, staff and students must be reviewed prior to departure for a variety of reasons. Please call (208) 282-1336 or email the Export Control Office with questions.
2. Purchasing from International sources - All international vendors must be cleared through Restricted Party Screening to ensure they are not banned as a procurement source or there are other export-related issues.
Prescreening is required whether buying with purchase card or purchase order.
Prescreen the vendor by contacting the Export Control Office either by email to firstname.lastname@example.org or by calling 208-282-1336 or 282-2618. A vendor that fails an export control clearance should not be used for ISU purchases.
Required info for vendor screening:
- Business name*
- City and Country of office that will handle the order
- A link to a website is not enough, please isolate a physical address
*Product names are not always the same as business names
3. Shipping to international destinations - for example: returning equipment for service or repair. sending samples to foreign laboratories for testing.
ISU Export Control Officer
Deb Easterly, Assistant VP
Research Outreach & Compliance
Export 101 Training (Bureau of Industry and Security, U.S. Department of Commerce)