Export Control & International Collaboration
Prior to undertaking any international research collaboration, researchers and institutions must first conduct a due diligence process.
A particular collaboration may not on first appearance be directly relevant to such activities. However, a transfer of technical information or data for one purpose could unwittingly be used for another purpose, including assisting in the development or production of WMD (Weapons of Mass Destruction).
You must check whether your potential collaboration partner individuals and their organisations have been involved in activities of potential concern. Guidance in relation to this can be located by clicking the button below. The National Protective Security Authority (NPSA) guidance on Trusted Research for Academia (https://www.npsa.gov.uk/specialised-guidance/trusted-research/trusted-research-academia) may also prove useful.
Please note, Export Control Joint Unit (ECJU) may be contacted for assistance via the Global Compliance team with specific enquiries if more information and advice is required.
Guidance on International Collaboration
The government of the country where collaboration parties are based will very likely have their own export control restrictions. You must ensure compliance with their regulations.
It should be noted that some technologies imported from the US may bring conditions with them. These conditions would be detailed on the US export licence or end-user documentation.
Any member of staff planning to receive technology from the US should speak with a Global Compliance Manager in QUB Research before accepting and signing general declarations of compliance or end-user documentation.
US EXPORT CONTROLS
If you import controlled technology / goods / software from the US, US Export Controls apply even after the item is no longer in the US.
Re-export rules may also prevent the sharing of technology / goods / software with certain foreign nationals within the UK. This includes researchers in the University who are from overseas or have dual nationality. This may apply to shared equipment and software used by students, postdocs and visiting academics.
If the technology is subject to ITAR (International Traffic in Arms Regulations) or EAR (Export Administration Regulations) controls, transfer to another party within or outside the UK may be prohibited unless cleared within the supplier’s licence. You should ask the supplier if the technology is subject to ITAR or EAR controls.
More information about US Export Controls and how they apply to Universities can be found on the HEECA website.
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What is a re-export?
A shipment or transmission of technology (or other item) subject to the EAR from one foreign (i.e. importing) country to another foreign country. It also refers to transfers within the importing country.
- What is a ‘deemed’ re-export?
‘Deemed’ re-export refers to restrictions in respect of non-US nationals – release of technology contrary to restrictions is deemed to be an export to that person’s home country even if it does not go there physically or there is no physical transfer to that person, this may require an authorization under the EAR.
- Incorporating EAR / ITAR controlled materials or items into technology
US export controls can still apply to US origin components even after they are incorporated into a foreign-made product. You may still require an authorization under the EAR. You should speak to your supplier or collaborator to establish if this applies to the goods / items / materials / software you are receiving.
Any member of staff planning to receive technology from the US should speak with a Global Compliance Manager in QUB Research before accepting and signing general declarations of compliance.