Export Control Measures
The Export Control Management Plan (ECMP) for research activity and projects at the UW applies to projects or activities that:
- Involve receipt of export controlled information from an outside party or sponsor, such as through a nondisclosure agreement or sponsored research agreement;
- Use equipment or software that was developed for military or space applications;
- Require a foreign national to know how a high-tech piece of equipment is manufactured, designed or repaired;
- Are not considered Fundamental Research; or
- Involve technology and software associated with export-controlled equipment.
Technology Control Plans
In those rare situations where specific data or hardware is subject to the export control regulations and, therefore, may not be shared with foreign persons without authorization, a Technology Control Plan (TCP) may be put in place. The Technology Control Plan is drafted by the Export Controls Office based on regulatory requirements, University policies and procedures, and research agreement language, as applicable. Technology Control Plans document the restrictions and the steps required to be taken by the research team to ensure compliance.
Using the TCP as a guide, the PI or Activity Director of a project/activity drafts a Security Control Measures Plan that contains specific information regarding the physical and personnel security controls that will apply to the project. The Export Controls Office is available to consult on the Security Control Measures Plan, as needed; contact firstname.lastname@example.org.
Security Control Measures Plan Components:
Details of your specific project or activity may require heightened and customized security measures, as assessed by the Export Controls Office. Any control measures above and beyond the standard University requirements must be integrated into the Security Control Measures Plan before it is finalized.
Initiating a Technology Control Plan
A Technology Control Plan (TCP) can be implemented at any time during a project or activity. Most often, this happens when an award is received for a research project that involves export controlled information.
Circumstances for review and implementation of a TCP:
- Restriction in award terms related to participation, publication, or government restrictions on the project results or information being shared on the project with the research team.
- Answers to eGC1 Compliance questions indicate collaboration with foreign parties and handling or development of export controlled information.
- Third party or side agreements, such as a confidentiality agreement, indicate there will be information, technology or software used on the project that is proprietary and includes restrictions on sharing technology, for national security purposes.
- Equipment will be developed or purchased on the project and the equipment is export-controlled.
At time of award, your Office of Sponsored Programs (OSP) reviewer or the Export Control Office’s Research Security Specialist will reach out for more information to assist in implementing necessary security measures.
If you believe your project involves export controlled information, you may also contact email@example.com to request a review of your project.
Commodity Jurisdiction Request
As part of the export control review, the Empowered Official may need to submit a Commodity Jurisdiction (CJ) request to the Department of State, Directorate of Defense Trade Controls (DDTC). DDTC will determine if the information is subject to the Export Administration Regulations (EAR) or the International Traffic in Arms (ITAR) regulations.
These CJ requests can ONLY be submitted by the Empowered Official; contact firstname.lastname@example.org.
Export Control Licensing
Before undergoing a research activity, you may need an export control license. Review when a license is required. License requests can only be submitted by the Export Controls Office; contact email@example.com.
At time of award, if the eGC1 compliance questions indicated a transfer or shipment of export-controlled information or items to a foreign national or abroad, the award will be held for review. The Export Controls Office will review these awards and if an export control license is needed, they will follow up with you.