U.S. export control laws and regulations, including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and regulations administered by the Office of Foreign Assets Control (OFAC), govern the export, release, or transfer of certain data, information, technology, software, equipment, and hardware to foreign countries or foreign persons for reasons of foreign policy, national security, and trade protection.

All UT Dallas employees, visitors, students, affiliates, and contractors are required to comply with applicable export control and sanctions regulations. Failure to comply may result in serious consequences, including civil and criminal penalties, significant fines assessed to both the University and individual researchers, and the suspension of research activities or programs.

How do export controls impact me at UT Dallas? 

Export control regulations may restrict the destinations UT Dallas personnel may visit, who they may work with, what items, information, technology, and knowledge may be shared outside of the United States, and what technology and knowledge may be shared with foreign nationals within the United States. As a result, export compliance review may be required for activities, including but not limited to:

• Shipping or carrying equipment, materials, samples, data, information, software, or devices outside of the U.S.
• Sharing controlled technology, data, information, or software to foreign persons.
• Conducting international research collaborations or sponsored research.
• Involving foreign nationals in projects that include export-controlled technology.
• Accepting contractual or sponsor-imposed restrictions on publication, proprietary information, or access.
• Engaging in activities involving restricted or embargoed countries, organizations, or individuals.
• Note: An export violation can occur even when you’re not physically shipping an item internationally. An export can occur when:
• Sharing export control restricted technology, data, information, source code, and software with a foreign national, even if they’re located in the U.S. This is called a deemed export.
• Emailing or otherwise providing written documentation or data.
• Oral communications.
• Visual inspection of, or access to, controlled technology, data, information, source code, and software, by a foreign national, even if they’re located in the U.S.

Fundamental Research Exclusion

The majority of research conducted at The University of Texas at Dallas qualifies as fundamental research and is therefore generally exempt from export control regulations under the Fundamental Research Exclusion (FRE). Fundamental research refers to basic or applied research in science and engineering conducted at an accredited institution of higher learning where research results are ordinarily published and shared broadly within the scientific community. The FRE may not apply when a research project includes:

• Sponsor or government-imposed publication approval requirements
• Access restrictions on research participation or results (including restrictions based on nationality)
• Use of proprietary, restricted, or export-controlled technology
• Contractual terms that limit dissemination or sharing of research outcomes

Not sure if your project is still “fundamental”? Contact our office at exportcontrol@utdallas.edu

How the Export Control Office Supports Researchers

When the Fundamental Research Exclusion does not apply, UT Dallas works in collaboration with researchers to ensure compliance with export control regulations through the following support mechanisms: 

• Reviewing research agreements and project terms for export control implications.
• Assessing whether export-controlled items, technology, or data are involved by performingexport control classifications and identifying applicable ECCNs.
• Obtaining export control licenses when necessary. 
• Implementing a Technology Control Plan (TCP) to manage access and ensure compliance.
• Advising on international collaborations, shipping, travel, and data sharing.

The presence of export control requirements is not meant to impede research. In many cases, appropriate controls allow research to proceed while meeting regulatory obligations.

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