Export Control Licensing

An export control license is the United States’ government mechanism to allow and track the transfers of export-controlled technologies. License requests must be submitted to the specific federal agency responsible; the Department of State for ITAR-controlled items, the Department of Commerce for EAR-controlled items, and OFAC for OFAC-controlled countries.

If a researcher has a project/technology that is export controlled and needs an export license to proceed, they must curtail the activity until an exception/exclusion is identified or a license is approved. Note that deemed exports may also require a license.

Each license is for a specific export transaction. If there is concern that a license may be required, please contact the Office of Research Integrity & Compliance (ORIC) as soon as possible to allow for a review of the application process.

Export Control Licensing Process

A license application and approval/denial can take up to six months for review before a final determination is made. The licensing process must be completed prior to beginning research on the project.

It can be time-consuming to obtain a license, so it is important that it is started as soon as possible.  Remember that the activity in question cannot take place until either an export license is granted or it is determined that a license request is not necessary.

Generally, to determine if a license is required, four questions must be answered:

  • What is being exported (is it controlled and which agency controls it)?
  • Where is it going or is it a deemed export?
  • Who is receiving it?
  • How will it be used?

Licensing Links