MODULE 7: Export Controls
Export Control (Basics)
The term “export controls” means the federal laws and regulations that have been created to control international commerce and safeguard national security. Princeton University has the same obligations as any other entity or party to comply with export control laws. Academic research normally is conducted openly and most research activities are not subject to export control regulations. However, even at an academic research institution there are certain conditions under which the export of tangible items, such as equipment or materials developed in the course of research, or intangible research results, such as technology or know-how (information or technical and scientific data about controlled equipment) developed in the course of research, either is prohibited or requires a license.
As an example, a researcher who is performing research sponsored by a German company may be required to send a prototype of optics equipment and related technology h/she is developing under the research project to the sponsor’s research laboratories in Germany. Before doing so, Princeton must first consider whether an export license will be required. It is important to keep in mind that certain “controlled items” or “related technologies" require an export license unless they meet the test that the research is in the public domain or is otherwise covered by the “fundamental research exclusion.”
Controlled Items
Items and services that have military applications, including commercial items that could have military applications (i.e., dual-use items) are called Controlled Items and may be subject to export controls.
Commerce Control List (CCL) - A list of items under the export control jurisdiction of the Bureau of Industry and Security, U.S. Department of Commerce. The CCL is found in Supplement 1 to part 774 of the Export Administration Regulations (EAR).
Munitions List (ML) - Articles, services and related technical data designated as defense articles and defense services pursuant to the Arms Export Control Act.
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