What happens if a proposed project does not qualify for the “fundamental research” exclusion and is therefore subject to export controls restrictions?

If a project falls outside the fundamental research exclusion (FRE), the Export Control Office will work with the investigator to reduce the compliance burden under the Export Administration Regulations (EAR) or International Traffic in Arms Regulations (ITAR).

For projects governed by the EAR, a license exception may be available, which would eliminate the need to obtain an export license. If no license exception applies, the Export Control Office may need to secure an export license from the appropriate federal agency before the investigator can begin the work.

If the project does not qualify as fundamental research, no license exceptions apply, and an export license cannot be obtained within a reasonable time frame or under acceptable conditions, the project must either be revised to meet the criteria for the fundamental research exclusion or it cannot be conducted at the university.