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Office of Research Security

Export Control FAQ

Do export control regulations apply to my research?

Export control regulations may apply if your work involves controlled technologies, restricted data, international collaborations, or sponsor-imposed restrictions. Most fundamental research is excluded, but exceptions apply when publication or access restrictions exist.

I’m a PI—when do export controls actually affect my project?

Export controls may apply if your project includes publication or access restrictions, controlled equipment/software, industry or defense sponsors, or international collaborators/participants. If your award or NDA limits dissemination or participation, contact ORS before work begins.

Do certain sponsors impose additional restrictions on foreign nationals or international collaborations?

Yes. Some federal agencies and programs may impose restrictions on foreign participation, access to controlled technology, or international collaborations. Contact ORS before involving foreign nationals or foreign institutions in projects with sponsor-imposed restrictions.

How do I know if a collaborator or entity is restricted?

ORS performs restricted party screening. You should contact ORS before engaging with new international collaborators, vendors, or partners to ensure compliance with U.S. sanctions and denied party lists.

What if my contract includes an NDA or export clause?

Route all agreements through OSP/General Counsel and notify ORS. Clauses that limit publication, access, or foreign participation can trigger export controls and remove the fundamental research exclusion.

What is a “deemed export”?

A deemed export occurs when controlled technology or information is shared with a foreign national within the United States. This can require a license depending on the technology and the individual’s country of citizenship.

I have developed a new technology, material, or invention. Do export controls apply?

Possibly. Certain technologies, materials, software, and inventions may become subject to export controls, particularly when commercialization, patenting, international collaborations, or publication restrictions are involved. Contact ORS for an assessment.

What are my disclosure obligations under research security requirements?

You must disclose foreign affiliations, appointments, and support in accordance with sponsor requirements (e.g., NSF Current & Pending Support, NIH Other Support). Failure to disclose can result in serious compliance consequences.

Can I share research materials, samples, software, or technical data with an international collaborator?

Possibly. Transfers of materials, software, technical information, or research data may be subject to export control regulations or other restrictions. Contact ORS before sharing materials internationally.

Do I need approval before traveling internationally for research?

You should consult ORS prior to travel if you are:

  • Taking equipment, software, or research data, or
  • Traveling to high-risk or sanctioned countries.

ORS can help determine if a license or additional safeguards are required.

I want to bring a visiting scholar or hire a postdoc—what should I check?

Verify whether the individual will access controlled technology or data. ORS can determine if a license is required and perform restricted party screening before onboarding.

I’m traveling for fieldwork or a conference—what are the risks?

Risks increase when traveling with research data, proprietary code, encryption, or specialized equipment, or when visiting sanctioned/high‑risk countries. ORS can advise on clean devices, data minimization, and any licensing needs.

Can I take my laptop and data abroad?

Usually yes for routine use, but restrictions may apply for certain countries, encryption, or controlled data. Use a “clean” device when possible and avoid taking controlled or sensitive data unless cleared by ORS.

What should I do before shipping items internationally?

ll international shipments must be reviewed for export control compliance. Clemson requires use of approved shipping processes and may require classification, documentation, or licensing prior to shipment.

What is “fundamental research exclusion” and why does it matter?

The Fundamental Research Exclusion (FRE) is defined under U.S. export control regulations as supporting basic and applied research whose results are intended to be published and shared broadly within the scientific community. Although the FRE can exclude resulting research information from export controls, it does not necessarily exempt controlled technologies, proprietary technical information, sanctions-related restrictions, or certain defense-related technical collaborations and activities.

My research is “fundamental.” Do I still need to do anything?

Often no, but confirm there are no restrictions in your proposal, award, or side agreements. The fundamental research exclusion can be lost if you accept publication controls or limit participation by foreign nationals.

Who do I contact if I’m unsure?

If you have any questions or are unsure whether export control or research security requirements apply, contact ORS before proceeding.