International Travel or Collaboration & Export Controls

Is your project subject to Export Controls? For example, are you shipping materials abroad, entering into collaborations with foreign businesses, or citizens, or traveling internationally? 

  • When do Export Controls apply? 
    • Generally
      • Export controls refer to federal laws and regulations governing the export of certain items, information and technologies to foreign entities and foreign nationals either abroad or in the U.S.  Export controls apply whether the research activity is federally funded or not. Failure to comply can result in severe consequences for individual researchers, including fines and imprisonment and limitations on future research.
      • Export controls not only apply to the physical exchange of certain types of technical information and software, but also to the transfer of such information to individuals from other countries, even while they are at Harvard, and an export license may be required. 
      • Export controls may apply to a number of activities in the academic research space, including shipping materials or equipment abroad, entering into international research collaborations with foreign entities, providing educational services abroad or travelling internationally.  See http://vpr.harvard.edu/pages/export-controls-policies-and-procedures for more details.
    • Licenses
      • If the project requires the transfer controlled technologies or information (i.e. prototypes, software or research results), a “license” must first be obtained from the relevant federal government entity:
      • Department of Commerce oversees the Export Administration Regulations (EAR),which is concerned with “dual use” items; i.e., items designed for commercial (civilian) purposes that can have military applications, such as computers, lasers and pathogens
      • Department of State oversees the International Traffic in Arms Regulations (ITAR),which is concerned with items that are military in nature, including equipment, software, algorithms and technical data and services directly related to those items.  The ITAR regulations also apply to the import of ITAR items.
      • Department of Treasury oversees the Office of Foreign Asset Control (OFAC), which administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals with respect to specified foreign countries and regimes as well as, terrorists, those engaged in proliferation of weapons of mass destruction, and other threats to U.S. national security, foreign policy or the economy. 
    • Contacts and Resources

Are you shipping items, samples or other materials abroad? 

Shipment of Items, Equipment, Samples or other Materials:  Consult with your School’s Export Control Officer prior to shipping or carrying any samples or materials abroad: even some seemingly ordinary commercial items and technologies may be controlled. 

  • Examples of controlled items: global positioning systems (GPS), thermal imaging cameras, encrypted software, the Ebola virus, etc.
  • License requirements also depend upon the destination, end-user or end use of the item or technology.
  • To expedite the license determination review: describe the item and include the specific destination, end-user and end-use of the item. 
  • Ask early and ask often.  Export Control Officers typically screen items quickly, but if a license is required, it could take up to 90 days for the government to issue the license.​​​​​​​

For lab supplies that are not found in country, Harvard has well-established relationships with vendors, and purchases can be done on behalf of the international site through HCOM. Shipments can be coordinated through commercial carriers like FedEx, DHL and UPS. Harvard Strategic Procurement also has an agreement with E. Sidney Stockwell, Co., Inc., a customs broker who can expedite deliveries into and out of the U.S. and most countries.