You are here

“Tools of Trade” License Exception

In order to use the “Tools of Trade” license exception, both of the following must apply:   

1. Personal requirements for Using “Tool of Trade” license exception:

  • You must be a U.S. person or the employee of a U.S. person,

  • Any accompanying family member must be a U.S. person,

  • You must take only the usual and reasonable kinds and quantities of items for use in a lawful enterprise or undertaking, or the trade, occupation, employment, vocation or hobby of you or an accompanying family member,

  • You must bring the items back with you upon your return or within 12 months,

  • You must keep the item under your effective control at all times rather than leaving it in your locked hotel room, and

  • You must take precautions against the unauthorized release of software and technology.

2.  Hardware, Software, and Data requirements for Using “Tools of Trade” license exception:

  • The laptops and other computing and data storage devices are all standard, off-the-shelf products and are generally available to the public through retail outlets.

  • The operating system and all software applications are generally available to the public and are either pre-installed on standard, off-the-shelf hardware or can be purchased and installed by a user without vendor support.

  • Any encryption is of the kind that is generally available to the public and does not allow for user revisions to enhance communications security capabilities. It is either pre-installed on standard, off-the-shelf hardware or can be purchased and installed by a user without vendor support. For more specifics on export controls and encryption, go to Export Controls on Encryption Software.  

  • Any data and analyses you take are publicly available (e.g., published in journals or published on the web). Data and analysis from research that ordinarily would be published and that are not restricted by contract from general dissemination can be treated as publicly available; and

  • There are no other export constraints on any of the equipment, software, data or information that would apply to your intended travel. Examples of items with export constraints that are not eligible for this exception include satellite or other space related equipment, components or software, high level encryption products, and defense items covered by the International Trade in Arms Regulations (ITAR).

PLEASE NOTE:  Duo two-factor authentication (2FA) devices are generally eligible for the “Tools of Trade” license exception, except when traveling to the embargoed countries.

If you would like to document your export compliance and self-assess that your electronic device complies with the Tools of the Trade license exception, you may download either the TMP for U-M-owned technology form or the BAG for personally-owned technology form to take with you when you travel.