Export Controls are a series of measures imposed by the UK Government to regulate the movement of controlled goods, software, and technology to other countries through licenses and restrictions.
They 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 controls include restrictions on sharing information verbally or accessing your own information while abroad. Different countries will have their own Export Control regulations. Be aware of this when making transfers.
Everyone in the UK must comply with Export Control legislation 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.
Know Your Partner: Who your partners are may affect restrictions on any items or information you wish to share with them. Make sure that you know your collaborators and any risks they present.
If you think that export controls apply to your research or research related activities please contact Claire Walsh (email@example.com) or Phil Wiles (firstname.lastname@example.org) in the Policy Integrity, and Performance Team.
UK export control legislation broadly fits in to the following categories:
Technology in the case of UK export controls means information for the development, production, or use of controlled goods or software, as well as some specific information described in the control lists.
An export can be any transfer of goods, software or technology. This includes traditional exports such as shipping machinery, as well as the transfer of information in both physical and digital forms eg via USB, via email, through phone conversations, at conference presentations, or on Zoom calls.
Generally UK export controls regulate movement between countries, regardless of the nationality of the person receiving the items or information. This means that actions such as taking your own information abroad, or accessing information via email or through the cloud while outside the UK, are considered exports.
Some export control restrictions apply even when goods are not being transferred from the UK to another country:
You must not export items you know or suspect may be used to make chemical, biological or nuclear weapons of mass destruction.
There are also controls on the
There are Government restrictions on certain non-UK persons studying specific subjects in the UK under the Academic Technology Approval Scheme. This scheme applies to subjects and research areas where knowledge could be used in programmes to develop Advanced Conventional Military Technology (ACMT), Weapons of Mass Destruction (WMDs) or their means of delivery. For ATAS enquiries, please contact: email@example.com.
When collaborating with international partners on research, it is necessary to undertake due diligence to ensure that you have a sufficient understanding of who your partners are. Please ensure that due diligence has been completed and see UK Government guidance on Export Control and collaborating internationally before engaging in international collaborations.
Even when collaborations do not initially seem to be related to issues of export control, the development of systems such as weapons of mass destruction require expertise from a range of areas, and information transferred for one purpose may later be used for a different controlled purpose by end users. Some countries have an active state policy of diverting advanced and emerging technologies to support the development of their military, including WMD capabilities.
Further guidance on conducting research internationally can be found on the University's Guidance on conducting research outside the UK web page and the Government's Trusted Research Guidance for Academia.
Different countries will have their own Export Control regulations. Be aware of this when making transfers.
There are some exemptions to UK Export Controls which mean that they do not cover certain areas of academic research. These exemptions fall into 3 areas:
This is technology or software available without restrictions on its further dissemination (excluding the normal copyright restrictions that may apply).
Export controls do not apply to research in the pursuit of basic scientific knowledge.
To qualify for this exemption research must:
Research with a low Technology Readiness Level (TRL) of around 1 to 3, is more likely to fall within the area of ‘basic scientific research’.
Nb. This only applies to dual-use technologies. This does not apply where there are end-use, end-user or destination concerns. By definition military listed technology is for a specific application, and therefore is not basic scientific research.
In the case of non-nuclear dual-use ‘technology’, the controls do not apply to the minimum technical information required to support a patent application.
More information about these exemptions can be found in this Guidance on Export controls applying to academic research from the ECJU.
The US has a variety of export control regulations including the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR).
These regulations apply to items even after they have left the United States and may restrict the re-export of items to other countries or the access other individuals can have to them (even where they are working within the University or on the same project). The regulations may apply even when only part of an item has US origins
For further guidance on UK legislation:
For information about US export control legislation:
For more University of York guidance:
Research Policy Officer (Compliance)
Research Integrity and Compliance Manager
Questions to ask of 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 (PDF , 52kb) for help determining if Export Control applies to your research.