Export Control

For information on UK export sanctions on Russia see here.

Background to export control

The United Kingdom has an obligation to ensure that goods, technology or software that can be used for a military purpose or contribute towards the proliferation of weapons of mass destruction are not exported into the wrong hands. To meet this obligation, and also to implement UN or EU sanctions, anyone who exports goods or technology must comply with export control legislation.

The Export Control Organisation has issued a short introductory film to explain Export Control and why it is important.

PLEASE NOTE: From 1 January 2021 export control requirements have been expanded to include all exports of controlled dual-use items and technologies to the European Union. For detail please see the University's guidance on exporting controlled items and technologies to the EU.

PLEASE ALSO NOTE that on 4 January 2022 the National Security and Investment Act came into force, which regulates transactions in 17 sensitive areas likely to give rise to national security risks. Adjacent to export control, this act empowers the government to impose conditions on qualifying acquisitions of entities and assets, or, to block or unwind certain transactions. For more information, see our webpage on the NSI Act.

Export Control at the University of Cambridge

The University of Cambridge is committed to complying with UK Export Control law. As such, the University has an Export Control Procedure and developed these webpages to help researchers fulfil their obligations under UK law. The Research Office also issued a guidance note on Export Control in March 2020 (please note that both this document was issued before 1 January 2021 and do not cover the changed requirements).

Who is most likely to be affected?

In the academic context, export controls are most likely to apply in relation to scientific and technical research with potential military or WMD applications, particularly relating to:

• the development of military and security-related goods, software or technology;
• nuclear science or engineering;
• missiles, aerospace and space technology;
• autonomous vehicles and stealth technology;
• some high strength materials and material production techniques;
• some chemicals with toxic properties;
• some viruses, pathogens and vaccines;
• some sensors and lasers;
• some high specification electronics and cryptography.

However all researchers, particularly those in the scientific and engineering disciplines, need to be aware of and comply with export control regulations. This forms part of the duty for all researchers to ensure that any University business they undertake is carried out in compliance with all applicable legal obligations (see the University’s Financial Regulation 3.1).

Compliance

The responsibility for compliance with export control regulations ultimately rests with the Principal Investigator (PI). Compliance with export control legislation requires the PI to consider whether they may need an export licence from the Export Control Joint Unit to carry out an activity and, if required, to obtain the licence before any export is made. Failure to obtain a licence when one is required or failure to observe the terms of a licence is a criminal offence for which the PI responsible is likely to be liable.

PIs, particularly in science and engineering disciplines, should ensure that they:

1. are aware whether their research may be subject to export control legislation;
2. have read and understood the University’s Export Control Policy and these guidance webpages;
3. consider the guidance on these webpages whenever embarking on an activity that could:
   • lead to the physical, electronic or oral export outside the UK of goods, software or technology:
     • that they have been informed by the Export Control Organisation are covered by export control.
     • that are covered by sanctions or embargo when exported to their intended destination;
     • with the potential for military or WMD use;
   • involve the transfer of knowledge within the UK for use in a WMD programme outside the UK;
   • involve the transit of goods, software or technology through the UK.

Next Steps

If you suspect that export control may apply to your work please:

1. Read these pages for initial guidance on export control.
2. Consider the basic awareness flowchart, scope and read the University's Export Control policy.
3. If you still suspect that export controls may apply to you work use the Export Control Organisation's Goods Checker Tool to establish if the items or technology you intend to exprot are on the control lists.
4. if you suspect that export controls may apply to work you intend to undertake, complete the Export Control Enquiry Form; and
5. Contact an Export Control Advisor (including a copy of your completed Export Control Enquiry Form.

The Research Office will work with you to decide whether a licence should be applied for or not. It should be noted, however, that the decision as to whether to apply for an export licence is a technical one that can only be made by someone with a good knowledge of the project concerned and the nature of the goods, technology or software to be exported. The decision will, therefore, rely primarily on the advice given by the PI.