Full Technology Evaluation

While the researcher can take the first steps described below for making a determination whether equipment or technology is controlled under the export regulations, a full evaluation needs to be performed by an OSP export control specialist with assistance from the researcher and/or administrator.  Resolution of any questions generally turn to technical aspects of the equipment or technology and thus the input from the researcher is imperative.

Step I

A useful starting place is the Do I Need to Be Concerned About Export Controls? Decision Tree.  A review of these questions may rule out any export control issues.  On the other hand, it may raise the question whether the equipment or technology is found on the CCL or the ML.

Step II

If it is necessary to determine whether equipment or technology being used or developed in the project may be found on the CCL or the ML, OSP has trained personnel and the tools required to make a definitive determination of the specific classification (or classifications) of the equipment or technology in question.  However, the researcher’s knowledge of the technical aspects of the equipment or technology is critical to this determination; any information that can be provided by the researcher by their own advance exploration of the CCL or ML or by providing answers for questions raised by OSP personnel, and in some cases outside counsel, will help lead to a quick determination of whether or not an equipment or technology is controlled, and if so, whether a license will be required.

Note! 

Past history has shown that in the majority of cases, a full evaluation will result in the determination that no license is required.  However, because the penalties for a violation of the regulations which could result if such a determination was not made before a controlled piece of equipment or technology for which an export license would be required was improperly exported (including a “deemed export” within the United States) can be so severe, it is imperative that this determination be made by the appropriate personnel within OSP prior to any export taking place.

 

Penalties for Non-Compliance

 

Back to Preliminary Technology Evaluation

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