Princeton's Policy on Export Controls
The University must fully comply with all United States export control laws and regulations, including the Export Administration Regulations (EAR) under the Department of Commerce, the International Traffic in Arms Regulations (ITAR) under the Department of State, and other such regulations imposed by the Treasury Department through its Office of Foreign Assets Control (OFAC).
Export control laws apply to an increasingly broad range of activities and technologies, including data (Covered Technology). An export license is almost always required to ship or otherwise transport a Covered Technology to a foreign country or to provide foreign nationals with training (e.g., under a technical assistance agreement) that involves a Covered Technology. Also subject to licensing are Deemed Exports, or transfers of controlled technology to foreign persons, usually in the U.S., where the transfer is regulated because the transfer is “deemed” to be to the country where the person is a resident or a citizen.
An export license is not required for research conducted on the University campus -- including research involving Covered Technology or Deemed Exports -- IF there are no publication or access restrictions on the research. The University’s strict policy of open access and publication provides protection under the fundamental research exemption. Fundamental research includes basic or applied research in science and/or engineering at an accredited institution of higher learning in the United States where the resulting information, in some cases, is ordinarily published and shared broadly in the scientific community and, in other cases, where the resulting information has been or is about to be published.
All researchers are responsible for recognizing whether the technology or equipment involved in their research might be a Covered Technology and for complying with export control law. The Office of Research and Project Administration (ORPA) is available to assist researchers in their compliance efforts and, when necessary, will seek support from outside consultants and counsel.