Export Control Regulations

Export Control Licensing

Export control laws are in place to protect U.S. national security, foreign policy, and economic interests without imposing undue regulatory burdens on legitimate international trade. An export control license is the U.S. government mechanism to allow and trace transfers of export controlled technologies. License requests must be submitted to the specific federal agency responsible; the Department of State for ITAR-controlled items, the Department of Commerce for EAR-controlled items, and OFAC for OFAC-controlled countries.

To determine if a license is required, four questions must be answered:

What is being exported (is it controlled and which agency controls it)?
Where is it going?
Who is receiving it and what is their citizenship?
How will it be used? (not needed in the case of ITAR-controlled items)

If a researcher has a project/technology that is export controlled and needs an export license to proceed, he/she must curtail the activity until an exception/exclusion is identified or a license is approved. Note that "deemed exports" may also require a license.

Only a designated ‘empowered official’ may apply for a license. Any request for an export license for a controlled item must be initiated through the Associate Vice President for Research/Director of the Office of Research Administration.

A license application and approval/denial can take up to 3-6 months for review before a final determination is made. Each license is for a specific export transaction. If there is concern that a license may or may not be needed, please contact the Office of Research Administration as soon as possible to allow for an analysis of the need and to process the application.