Why is Export Control important to Jefferson and you?
- To protect your intellectual property
- To protect U.S. national security from foreign policy and economic interests
ATTENTION: To all Deans, Department Heads, PI & Research Staff Members
To ensure institutional compliance with export control, it is of paramount importance for individuals within the Jefferson community to be conversant with what types of activities may trigger an export control issue. As a result, having a fundamental understanding of the topic will allow members of the Jefferson research community to be able to know when to raise questions and alert Jefferson's Office of Research Administration to a possible export control issue. Aside from information that can be shared by Jefferson’s Export Controls Officer, you are encouraged to refer to the following websites: Essentials of Export Controls and the Directorate of Defense Trade Controls to augment your knowledge of the topic.
Unsure if your research project may be subject to export controls?
What you need to know
An export is:
Any oral, written, electronic or visual disclosure, transfer or transmission to any person or entity of a controlled commodity, technology or software/codes with an intent to transfer it to a non-U.S. entity or individual, wherever located (even to a foreign student or colleague at TJU or within one of its controlled affiliates).
Any transfer of these items or information to a foreign embassy or affiliate.
Deemed export involves providing, transferring or disclosing technology, information to a foreign national within the U.S. The following are examples of transmittals that may constitute deemed export:
- Telephone conversations
- E-mail communications
- Computer data
- Tours of labs
- Face-to-face discussions
- Training sessions
Generally, most research conducted at Thomas Jefferson University is excluded from export control rules because of the fundamental research exemption. However, under certain circumstances, these fundamental research exemptions may be lost or do not apply. Fundamental research is defined as basic and applied research in science and engineering, the results of which ordinarily are published and shared broadly within the scientific community, as distinguished from proprietary research and from industrial development, design, production and project utilization, the results of which ordinarily are restricted for proprietary or national security reasons.
Take the following questionnaire to determine if your research project subject to export control:
Use this questionnaire when reviewing:
- requests for proposals or project solicitations
- program award notices
- Non-Disclosure Agreements (NDAs)
- any other documents related to research proposals, contracts, cooperative agreements, and other arrangements for sponsored research projects