Is My Project Export Controlled? More Information

Your program may be export controlled if you answer YES to any of these questions:

  1. Are there any clauses that identify export restrictions?
    • The existence of an ITAR or EAR clause referring to export controls means that the program might be export controlled. Contact the ECO, who may need to interview you to make a determination.
  2. Does the project contain any export controlled equipment, data technology, or software?
    • The ECO may need to interview you to make a determination.
  3. Is there equipment controlled under the ITAR or EAR that needs to be exported to or accessed by non-U.S. persons?
    • We have worked to identify the most probable items that are export controlled, relating to space instrumentation, optics, detectors, including focal plane arrays, deformable mirrors, space-qualified adaptive optics, radiation hardened electronics, digital signal processors, atomic clocks, etc.).
    • If you are collaborating or otherwise working with a non-US person who needs access to export controlled equipment or technical data (e.g., a Co-PI, Co-I, Collaborator, Post Doctoral Fellow, Visiting Scientist, Research Associate, Student, or Contractor,), please contact the ECO. We may need to apply for an export license. For export procedures, see home page.
  4. Are you sharing, shipping, releasing or exporting software or source with non-standard encryption? (Or are you using open source encryption and adding your own script?)
    • If yes, contact the ECO. If it is newly developed software, it may need a classification or review to determine if it needs to be submitted to Bureau of Industry and Security prior to upload or transfer.
  5. Will there be export-controlled data published or presented to non-US persons? For example, technical data related to certain space instrumentation mounted on or used in satellites, certain ground-based instrumentation mounted on ground-based telescopes, data or software related to propulsion and control systems, etc.?
    • If yes, contact the ECO who will work with you to determine if it has export control restrictions that need to be resolved prior to release.
  6. Does your sponsor impose any publication restrictions?
    • If yes, contact the ECO
    • If you accept confidential or proprietary information subject to a Confidentiality or Non-Disclosure Agreement, and the disclosure restrictions affect your ability to publish research results, the research itself could lose its characterization as "fundamental research" for export control purposes.
  7. Does the award include foreign national restrictions?
    • This may be an indication that the sponsor considers this program to be ITAR-controlled. Please contact the ECO to make a determination if you require a Technology Control Plan.
    • Foreign nationals of certain countries may not be eligible to work on an export controlled project.
    • Should the research entail information or software identified on US export control lists and you wish to have foreign nationals participate in the research, you may be required to obtain an export license.
  8. Is there any involvement with countries or persons from sanctioned countries: Cuba, Iran, North Korea, Sudan and Syria?
  9. If you still are not sure if your program is ITAR or EAR controlled, use the Determination of Applicability form, or contact the Export Compliance Officer at


Section Photo