Export controls

What are export controls?

Export Control regulations and legislation may apply to your research if you transfer certain items or information to other countries, and in some cases between individuals in the UK. The aim of Export Controls are to prevent weapons of mass destruction (WMD) proliferation, human rights abuses, and to counter international threats such as terrorism. The controls include restrictions on sharing information verbally or even accessing your own information while abroad. Different countries will have their own Export Control regulations. You should be aware of this when making transfers.

Everyone in the UK must comply with Export Control legislation administered by the UK Government’s Export Control Joint Unit (ECJU). The ECJU grants licences for military and duel use (designed for civilian but used for military purposes) items. It is a criminal offence if and it is therefore the responsibility of researchers to ensure their activities are compliant. Export controls are more likely to apply to your work if it is in a high-risk research area.

If you think that export controls apply to your research or research related activities please contact researchgovernance@hull.ac.uk.

Key questions regarding your research

• Will I be exporting any controlled items or information?
• Is there any chance my research could be put to military purposes or used in the development of weapons of mass destruction (WMDs)?
• Do I know my partners and any risks they pose?
• Are there any sanctions on the country, person, or organisation I am transferring to?

Use the Export Control Guidance Flowchart for help determining if Export Control applies to your research.

Red flags

Even if your goods, software etc. is not on one of the UK Strategic Export Control Lists you may still need a licence if they are intended to be used or may be used (duel use) for military purposes or an EMD programme (End Use Controls). You may wish to

• You have not heard of the collaborator before or had any prior dealings (please conduct a due diligence review)
• Your collaborator is reluctant to offer clear information, either about the end-use of the items or engage in normal communications during contract negotiations, or NDAs are used excessively;
• The collaborators stated use for the items does not align with their normal business, or an aspect of the item (such as spare parts) are ordered excessively;
• Substantial incentives to provide the items are offered;
• The collaborator declines routine services, such as training provision, installation, and maintenance;
• Unusually favourable terms such as higher price and/or lump-sum cash payment are offered;
• Unusual shipping arrangements are requested – i.e. location, packaging etc;
• The collaborator or the installation site are subject to excessive security / restrictions for the items being shared

Further guidance

For further guidance on UK legislation:

• Export controls applying to academic research
• UK Strategic Export Control Lists
• Export controls: dual-use items, software and technology, goods for torture and radioactive sources
• Export controls: military goods, software and technology
• End Use Controls: WMD
• End Use Controls: Military
• UK Government Sanctions

For information about US export control legislation:

• US Export Control: ITAR
• US Export Control: Export Administration Regulations Introduction