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Export Controls

Export controls are a legislative framework, by which HM Government controls the export of a range of military and “dual-use” items. These are in place to promote global security and facilitate responsible exports. UCL has a vibrant and extensive international collaborative research environment. However, some of the knowledge held, goods used and activities conducted by UCL staff and students may have the potential for misuse or dual-use. When UCL works with international partners, some of these activities may be subject to export controls. Controls cover not just tangible goods but software, data, technology and know-how.

When do Export Controls apply?


Export controls and trade sanctions apply to all UCL staff and students and the University who engage in the transfer or export of controlled goods and related information abroad. 

Controlled goods include:

  • military items
  • firearms
  • items that can be used for torture or capital punishment
  • radioactive sources
  • goods subject to trade sanctions
  • dual-use items (goods, technology, software, documents or diagrams, which meet certain technical standards and could be used for military or civilian purposes or are considered proliferation-sensitive due to their technical possibilities or suspected end-use of concern)

Exporting can take place via physical or electronic means and includes:

  • transporting, shipping or freight overseas (including carriage of a laptop, a smartphone, or a memory stick on a trip)
  • any electronic transfer (such as fax, email, telephone, text message or video conference) from within the UK to a person (eg collaborator) or place abroad;
  • accessing controlled technology held on an intranet or cloud computing to other shared data environments while overseas; and
  • oral transmission by telephone or in the course of a presentation to persons located outside the UK could be within the scope where the details of the controlled technology are read out or otherwise communicated.

Compliance with export control legislation is a legal requirement


It is a criminal offence to contravene export controls or trade sanctions.

Any individuals and the University involved in breaching these laws risk:

  • very significant financial penalties
  • up to 10 years of imprisonment
  • harming others (including humans, animals, environment), if research is taken and used with the intent of causing harm

Compliance with export control should also be seen as part of the broader responsibility for research integrity. Failure to meet relevant legal requirements falls under the ‘Procedure for investigating and resolving allegation of misconduct in academic research (pdf)’.

How do I comply?


There may be instances where an export licence from the Export Control Joint Unit (ECJU) is required to carry out an activity in the course of the research. Such requirements may arise at different stages of the research life cycle: during research design, project development, disseminating research output, etc. 

You can use the Export Control Organisation's Goods Checker Tool to establish if the items, software, or technology you intend to export are on the control lists - remember that this list is regularly updated every couple of months.

You also need to keep in mind that some materials that are not on the control list, might nonetheless be subject to the legislation due to their technical possibilities or suspected end-use of concern:

  • if there is a suspected connection with use in a Weapons of Mass Destruction program
  • (suspected) military end-use in a country subject to an arms embargo
  • (suspected) use of the item as a component in military equipment
  • reasons of national security
  • human rights considerations

For help, support, advice and guidance on export controls, please email ec.nsi@ucl.ac.uk.

Export Controls Enquiry Form​

Training for academic departments


For an overview of Export Controls and how they are managed at UCL, watch our training session for academic departments (UCL login required). The session will help you understand how Export Controls might apply to your work, and offers practical tips on what to do when faced with an Export Controls query.

Export Controls Training 

For more information visit


 

Gov.uk

Export controls applying to academic research

Information on how the UK's strategic export controls apply to academics, university researchers and their institutions, and when an export licence is needed.

Gov.uk

Export Control Joint Unit

The Export Control Joint Unit (ECJU) administers the UK's system of export controls and licensing for military and dual-use items.

Gov.uk

OGEL and Goods Checker Tools

The Goods Checker Tool helps to establish if your items are controlled and identify the appropriate control entry ('rating') from the UK Strategic Export Control Lists.