The range of research activities at Harvard is broad and deep. Across numerous fields, Harvard scholars seek to expand human knowledge through analysis, innovation, and insight. Researchers include faculty members, visiting scholars, post-doctoral fellows, and graduate and undergraduate students, and they collaborate with colleagues across the University, at affiliated institutions, and at other research institutions in the United States and around the world.
During the course of such open research, Harvard faculty, staff, and students will likely, at one time or another, intersect with federal regulations that impose access, dissemination, or participation restrictions on the transfer of items and information regulated for reasons of national security, trade sanctions policy, anti-terrorism, or non-proliferation. Those regulations are called US export control regulations. Harvard is fully committed to complying with all laws and regulations that pertain to the conduct and dissemination of our research, including export control regulations.
What kinds of activities might trigger export control issues?
In the context of higher education, export control regulations apply most frequently to international collaborations, foreign travel, and shipping or carrying items to other countries. When export controls apply—for example, when we use disclosure-restricted technical information to generate our fundamental research or hand carry items outside the US in our baggage—the export of regulated items, information, or software may require approval from the US Government in the form of an export license. An export license permits "controlled" tangible items or software to be sent outside of the US, or controlled information or software code to be shared with foreign persons, either in the US or abroad.
Most of the information or software that Harvard shares with its colleagues and research partners is not export controlled or subject to trade sanctions, and the majority of tangible items that Harvard exports (like materials, prototypes, components, or equipment), do not require export licenses since they are generally not destined to countries of concern or to individuals or organizations subject to US embargoes or sanctions. However, all Harvard personnel are required by the Harvard Export Control Policy to demonstrate their due diligence and to document their adherence to US export controls and trade sanctions laws when such laws apply.
Before undergoing activities involving non-U.S. persons, places, or entities, including hosting international visitors on campus, Harvard personnel should contact their local export control administrators to conduct a screening. If it is determined that an export license is needed, the export control administrator will work with the Office of the Vice Provost to apply for a license from the government, according to University's Export License Review and Approval Policy.