If an Export is not eligible for an exclusion, then it is subject to Export Controls regulations and must be managed. The following is a non-exhaustive list of activities that will require management:
- Export of commodities
- Export of items produced during non-fundamental research
- Export of encryption technology
- Export of items related to industrial development, design, and production
- Export of items produced during research performed outside the US
Exports of Controlled Items will be prevented via a Technology Control Plan. If the Export of a Controlled Item cannot be prevented, then it must be classified and licensed according to the regulations.
Technology Control Plans
If a research project cannot be considered Fundamental Research, or if a project comprises items that would usually be subject to Export Controls, then Researchers will create a Technology Control Plan (TCP). This document details how the Researchers will prevent unintended export of research commodities, software, and technology. A TCP addresses physical security, information security, Personnel qualifications, training, international travel and collaborations, and other topics. The completed TCP will be reviewed by ORGS and OIT. All Personnel involved with the project must be listed on the TCP, complete the required training, and adhere to the provisions of the TCP. A TCP must be renewed every year.
Classification and Licensing
Most Controlled Exports can occur if they are properly classified and licensed. This process can take weeks to months to complete, so it is best to begin as soon as you know a Controlled Export must take place. ORGS will direct the classification and licensing process in collaboration with the Researcher.