US export controls
Guidance around export controls for goods, software, or technology originating from the USA.
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US export controls: overview
US export controls may apply to UK universities if research involves US-origin goods, software, or technology. These laws apply even outside the US and can restrict who may access controlled items, how they are used, and whether they can be shared internationally.
Key frameworks
- ITAR (International Traffic in Arms Regulations): Covers military and defence items on the US Munitions List.
- EAR (Export Administration Regulations): Covers dual-use items (civilian but with potential military applications), listed on the US Commerce Control List.
- EAR99: Covers most other US-origin items, which are still restricted in certain destinations.
What this means in practice
- Deemed exports: Allowing a foreign or dual national access to US-controlled technology (even within the UK) can count as an export. This includes lab access, software sharing, training, or even visual inspection.
- Re-exports and retransfers: Passing on US-origin items or technology to third countries—or to other people within the UK—may require a US licence.
- Incorporated items: Non-US products that include US-origin components or are based on US technology may also be subject to US controls.
- End-use restrictions: US authorities monitor how controlled items are used, and licences may limit collaboration with certain countries, organisations, or individuals (see the US BIS lists of parties of concern).
Implications for researchers
- Contracts and purchases: US suppliers may require End User Undertakings or compliance statements. Do not sign without University advice.
- Access in research groups: Restrictions may apply to international staff, students, and visitors.
- Sanctions: US sanctions can block use of US-origin equipment or software with certain partners (notably in China, Iran, and other restricted destinations).
Responsibilities
- Exporters (suppliers) must notify you if US controls apply—but University researchers are responsible for compliance.
- If your project involves US-origin items, always check the licence conditions and restrictions.
- Never agree to blanket compliance clauses without review.
Support and advice
If you are working with US-origin goods, software, or technology, or if a collaborator asks you to comply with US export control law, contact the University’s Export Control team (exportcontrol@sheffield.ac.uk).