Export Controls Overview
The United States Government controls exports of sensitive equipment, software and technology as a means to promote our nation's security interests and foreign policy objectives. Through the export control system, the U.S government can effectively provide for national security by limiting access to the most sensitive U.S. technology and weapons; promote regional stability; considers human rights; prevents proliferation of weapons and technologies, including weapons of mass destruction, to end users and supporters of international terrorism; and comply with international commitments including the UN Security Council.
These web pages have been designed to provide faculty, students and staff with access to resources to assist researchers and the university in keeping compliant with federal laws and guidelines.
Export Policies and Explanations
Export controls present unique challenges to universities and colleges because they require balancing concerns about US economic vitality and national security with traditional concepts of academic freedom and dissemination of research results. University personnel need to be aware that export control laws and regulations may apply to their research and creative practice, whether sponsored or not.
On February 1, 2016, the Grand Valley State University President's Cabinet approved the following Export Control Policy.
Federal laws govern how items, technology, and data may be exported from the United States or shared with foreign persons within the United States. Export control concerns can sometimes arise as part of research activities. It is therefore important that the Office of Research Compliance and Integrity is aware of the types of research projects in which GVSU faculty are engaged.
To help us better understand the types of research activities occurring on campus, and therefore better help our researchers address any potential export control concerns, please complete this Export Control Questionnaire on an annual basis (and update it whenever research activities change) and submit it to email@example.com.
Technology Control Plan
A Technology Control Plan (TCP) assists researchers in protecting and complying with government controls regarding their research projects for software, data or materials that are subject to U.S. export regulations. After filling out the Export Control Questionnaire, the Office of Research Compliance and Integrity will work with you to determine if your research requires a TCP. If one is required, please complete the following Technology Control Plan (pdf) form and send it to firstname.lastname@example.org. ORCI will work with you to ensure the completion of the form.
Guidelines for Faculty Traveling Abroad
When you travel from the United States to another country, everything you take is termed an “export.” Your items of personal effects (i.e., clothes, toiletries, medicine, etc.) are usually an exception and are in compliance of Export Administration Regulations (EAR). This is called EAR’s BAG Exemption (personal baggage). However, personal electronic devices (i.e., laptops, tablets, PDA, flash drives, and research items) can be distinctively different and may require a license by EAR, depending upon the specific make/model of the equipment, your destination, etc. If you are travelling internationally on behalf of the university, and will be transporting any university-owned devices, data, and/or materials beyond a standard GVSU-issued computer/phone, please contact the Office of Research Compliance and Integrity. The ORCI will determine if an export license is needed. For most destinations and technologies, a license will likely not be needed. However, if a license is required, it can often take several months to obtain, so you are encouraged to contact our office as early as possible.
****If you are traveling to any sanctioned country (Cuba, Iran, Syria, Sudan, or North Korea), you MUST contact the Office of Research Compliance and Integrity prior to your trip.****
Visiting Scholar's Guidelines
Most research conducted on Grand Valley campuses is excluded from export control regulations...
However, university research involving specific technologies controlled under the Department of State, and/or the Department of Commerce may require GVSU to obtain prior approval from the appropriate agency before allowing foreign nationals to participate in controlled research and/or sharing research – verbally or in writing – with persons who are not US citizens or permanent residents. Export control regulations affect not only the research performed on campus but shipping items or professional travel outside of the US. Simply traveling to a sanctioned country could require a license from the Department of Treasury.
Export controls, as it relates to research, is a responsibility of the Research Administration of Grand Valley State University. The Research Administration has developed researcher guidelines based on federal regulations and compliance. The Vice Provost of Research Administration serves as the University's Empowered Official. If you have any questions regarding export controls please contact our office (049 James H. Zumberge Hall) at (616) 331-9137 or email@example.com.
To learn more about Export Control, you can contact the Office of Research Compliance and Integrity (firstname.lastname@example.org; 616-331-3197) and/or complete online training through CITI. Grand Valley State University supports CITI for training of faculty, staff, and students in an effort to develop research best practices and safe research procedures.