University Activities

The Ohio State University conducts innovative research and fosters a research environment conducive to the creation and dissemination of knowledge for the public good. As part of this mission, the university continues to expand its research and other collaborative efforts with foreign countries and their citizens. All such activities may be subject to federal regulations covering certain exports with destinations and persons outside of the United States. In some cases, these regulations also apply to non-United States citizens at the university and within the United States.

University Interactions

Interactions can be research collaborations, educational exchanges, financial transactions, etc. If you anticipate the need to interact with a restricted party, party of concern or sanctioned region, please contact us.

Deemed Exports

Even when Ohio State is not sending any technical data/technology or physical items to another country, certain research activities taking place in the United States may still be subject to export control regulations. A deemed export occurs when controlled technical data/technology is transferred or released to a foreign person in United States. Because the majority of Ohio State’s activities are exempt from export control regulations, it is important to be aware when activities are subject to the regulations so that Ohio State can ensure compliance.

Receiving or Generating Data, Technology or Items

Controlled technical data/technology and items can end up on campus in a variety of ways. We can receive it from other parties or we can generate it. Sharing export controlled technical data/technology (even the technical data/technology associated with physical items) with foreign persons here in the United States is a deemed export. Please contact the Office of Secure Research prior to receiving or generating export controlled technical data/technology or items.

Physical Exports

Whenever a physical item enters the United States, regardless of its origin, it is subject to export control regulations when it leaves the United States. Our office will determine license requirements prior to physically exporting any items.

Physical exports happen:

  • During international travel when physical items are transported (regardless of whether they are sent ahead of time or hand carried)
  • During international travel when electronic devices are brought containing controlled technical data/technology
  • When items are shipped (in any quantity) to another country by any method (even if the item is returning to its country of origin). If a physical export is needed, contact the Office of Secure Research in advance.

International Field Work

Export Controls may apply when:

  • Research takes place outside of the United States. The research results research taking place outside of the United States may not qualify as Fundamental Research.
  • Equipment or items are taken or shipped out of the country. Even if the items are coming back to the United States, this would be considered a Physical Export.

Contact us if you plan on doing any international field work so that we can help you ensure all export control regulations are followed.

International Travel

International Travel can intersect with export control regulations based on where you are going, who you will be interacting with and what you are taking with you.

If you are going to a sanctioned country or region (Cuba, Iran, North Korea, Sudan, Syria, the Crimea region of Ukraine), contact us as soon as possible so that we can review the regulations and ensure that your travel activity is covered by a General License.

It is important to ensure that you do not export restricted information or provide any type of assistance to a restricted party. Our office can quickly determine if parties you intend to visit or collaborate with are on a restricted party list. Contact us for assistance.

If you are taking Ohio State items and equipment, even temporarily, those physical items are being exported. Please refer to the chart below for the ECCNs for equipment most commonly taken abroad. If you are planning to take equipment that is not listed in the chart below, please contact us so that we can determine whether an export license is required prior to your trip. 

Most commercially available basic software can be exported without a license. However, proprietary software, software that includes encryption and/or other complex software may require an export license and should be reviewed by the Office of Secure Research. Please contact us at exportcontrol@osu.edu if your device contains the above software or if you are taking includes any of the above software.

ECCNs for Common Travel Items*

*Do NOT use this chart for travel to a sanctioned region like Cuba, Iran, North Korea, Sudan, Syria or the Crimea region of Ukraine.

ITEM

ECCN#

LICENSED AUTHORITY

Dell Laptop (no encryption)

4A994

No Licensed Required (NLR)

Mac Laptop

5A992

No Licensed Required (NLR)

IPhones & IPads

5A992

No Licensed Required (NLR)

Jump/Flash Drive (most)

3A991

No Licensed Required (NLR)

Android Cell Phone/Tablets

5A992

No Licensed Required (NLR)

Garmin GPS

7A994

No Licensed Required (NLR)

International Collaborations and/or Presentations

Ohio State has launched the International Risk Assessment Tool to assist the research community to consistently and transparently identify international activities that may present an elevated risk to the university. The tool considers the unique factors of each engagement such as the specific activity, the level of Ohio State engagement, the location of the activity, and entities and personnel involved. This tool facilitates the conduct of international activities by allowing low risk activities to proceed without delay or extensive compliance checks, while flagging those potentially problematic activities for additional institutional review and approval.

In general, collaborations between university personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve any one of the following:

  • Restricted Parties
  • Parties of Concern
  • Persons in sanctioned countries
  • The shipping of physical items to a foreign party
  • The exchange of export controlled technical data/technology

Before engaging in an international collaboration, the university needs to determine if export licenses are required and to verify that the foreign individual and/or organization are not blocked or sanctioned parties. Ohio State faculty, staff and students are encouraged to complete the International Risk Assessment Tool prior to engaging the Office of Secure Research for additional review.

Disclosures, Presentations and Visitors

Questions

The Office of Secure Research can assist with any of the topics above and can support your training needs. Contact us at exportcontrol@osu.edu for questions.