While Princeton’s policy on export controls is based primarily on the need for open access and publication and preserving the protection of the fundamental research exemption, it recognizes that there may be times when a license is required when a controlled equipment or technology is an important element of a research project. When this is the case, it is imperative that the researcher recognize that they are dealing with potentially export controlled equipment or technology and work closely with ORPA to determine whether a license is needed for the completion of the research project and whether the University will consider applying for one in accordance with it's policies.
In the event that a license is required, the researcher is an important participant in determining the classification of the controlled item. This may require the researcher contacting the vendors providing the controlled equipment or technology for their assistance with this determination, as well as negotiation by ORPA or Purchasing of purchase orders that may include export control provisions. The researcher is also needed for preparing the technical aspects of an export license application and for responding to any federal agency questions regarding the research. And if a license is granted, there are generally provisos that are part of the license that dictate how the equipment or technology may be used in the course of the research that the researcher is responsible for complying with.
As ORPA is responsible for the management of Princeton’s export control issues and any licenses that may be required for Princeton research, it is imperative that the researcher engage ORPA as soon as an export control issue is identified so they can address the issue in a timely manner so that there will be no delay of the research project.
For more details regarding the license application process, see http://www.bis.doc.gov/licensing/bis_exports2.pdf