Export Control Regulations
U.S. citizens traveling abroad should be mindful that export control regulations do apply to items (defined as technology, equipment, software, and technical data in physical, digital or oral form) being taken out of the country. "Items" on the International Traffic in Arms Regulations’ (ITAR) U.S. Munitions List may not be taken out of the country without an export license. "Items" that are listed on the Commerce Control List (CCL) by the Export Administration Regulations (EAR) may or may not need a license, depending on the technology of the item and the destination country. Even readily available items such as GPS and laptop computers can be regulated depending on the destination country or the technology within.
One exception to export control regulations are the "tools of the trade" (general equipment and devices commonly used in the normal course and scope of a person’s profession). If using the "tools of the trade" exception, the traveler must retain effective control and ownership of the item. Blackberries, laptops with encryption technologies can be exported using this exception to most countries. Please note that technical data carried on laptops, flash drives, and other devices may also be subject to the ITAR or the EAR. International travelers should be diligent in knowing what data is stored on these devices before traveling.
Destination restrictions vary but can have a significant impact on what can and can not be exported. Technologies may not be exported without a license to countries that are subject to trade sanctions or embargoes administered by the Office of Foreign Assets Control. (This list changes frequently so please see their website at http://www.treas.gov/offices/enforcement/ofac/programs/index.shtml to see a list of countries under current sanctions.) Other destinations such as Canada or Belgium have fewer restrictions but still have an impact on what technologies and data can be exported to them.
Travelers should also note that communicating technology, technical data, or software to a foreign person anywhere in the world is deemed to be an export to the recipient’s country of citizenship. If a license is required for the physical export of the technology, technical data or software, it is also required for a deemed export. Therefore, care should be taken in presentations, conversations, and cocktail conversations with foreign persons regarding communication of technology or technical data that is or may be export controlled.
An item that does fall on the CCL can be exported if an export license is granted. If a traveler wishes to take a controlled item/data internationally, please contact the Office of Research Administration to verify that an export license is needed and to apply for a license. Please allow at least 60 days prior to date of travel for the processing of the license application and response from the applicable federal department.
If you are preparing to travel and have questions about the items you wish to take, please contact the Office of Research Administration at 494-6840 or you may send a description of your request to firstname.lastname@example.org.
For further reference, see ITaP’s Secure Purdue travel page.
Export Control FAQ
What are U.S. Export Control Regulations?
- Export Administration Regulations
- International Traffic in Arms Regulations
- Office of Foreign Asset Controls
- Denied Persons List
- Does the EAR apply to fundamental research conducted at Purdue University?
- What is the purpose of the International Traffic in Arms Regulations (ITAR)?
- Does the ITAR apply to fundamental research conducted at Purdue University?
- What are the responsibilities of the Principal Investigator conducting work that is controlled under the EAR, ITAR or OFAC regulations?
- Are there other regulations to consider?