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Export Guidance - Traveling Internationally

Overview

If you are planning to travel internationally you should be mindful that export control regulations do apply to technology, equipment, software, and technical data (in physical, digital or voice-transmitted form) being taken out of the country. Following are several university resources on international travel.

Whenever you take equipment, devices, computer software or technical data on a trip outside of the country, you need to comply with United States export statutes and regulations. In most situations, you will not need to obtain permission from the government to take the items with you and you likely will not need to take any special actions to comply with the export rules. Most of the equipment and data that you are likely to take with you are not specially controlled to most countries. As discussed in greater detail below, there is a broad exception to the export rules for taking tools of trade, with only a requirement of maintaining control; and the export rules generally will not restrain you from taking commercially available laptop computers and standard software to most countries.

Temporary Travel (less than a year)

If you will be temporarily traveling (less than one year) outside of the United States, you may take with you for activities related to your travel laptop computers, other portable computing devices, data storage devices and other equipment that people in your discipline would generally recognize as tools of trade as long as you maintain effective control of those items while you are outside of this country AND you are not traveling to an embargoed country (Cuba, Iran, North Korea, Syria or Sudan). You maintain effective control over an item when you either retain physical possession of the item or you secure the item in such an environment as a hotel safe, a bonded warehouse, or a locked or guarded meeting or conference facility.

If ALL of the following apply...

  1. The laptops and other computing and data storage devices are standard, off-the-shelf products and are broadly available; and
  2. The operating system and any encryption capabilities are of the kind that are preloaded on the computers and do not allow for user revisions to enhance communications security capabilities; and
  3. All of the application programs are general, commercially available software that either do not perform technical analyses; or, are general purpose scientific or engineering programs that are commercially available (e.g., for electric field calculations not aimed at a specific product); and
  4. All of the data stored on the computers or storage devices is publicly available (e.g., published in journals or on the web). Data and analyses from research that ordinarily would be published and are not restricted by contract from general dissemination can be treated as publicly available; and
  5. You have no reason to believe that there are export constraints on any of the equipment, software, data or information that would apply to your intended travel; and
  6. The travel is not to a country with special strong export controls, currently:
  • Cuba
  • Iran
  • North Korea
  • Syria
  • Sudan

...then you may qualify under the "Tool of Trade" license exception to travel with university-owned equipment and software.

There are many other devices and equipment for which there are minimal constraints under the export rules. If you have an issue with regard to maintaining effective control over an item, you might check with the people identified in the first paragraph above.

Items that require specific guidance:

You should not take with you ANY of the following without first obtaining specific advice of the export controls officer:

  • Data or information received under an obligation of confidentiality.
  • Data or analyses that result from a project for which there are contractual constraints on the dissemination of the research results.
  • Computer software received with restrictions on export to or on access by foreign nationals.
  • Devices or equipment received with restrictions on export to or on access by foreign nationals.
  • Private information about research subjects
  • Devices, systems or software that was specifically designed or modified for military or space applications.
  • Classified information
  • Device and/or technology restricted by federal export control regulations, such as MTokens.

You should keep in mind and be prepared for the potential that customs inspectors in countries that you may visit, and in the United States when you return, may require that you allow them access to inspect the devices and equipment you have with you and all of the contents of the computers and storage devices. In the United States, the inspectors may take possession of those items for various periods of time, and even permanently depending upon the circumstances. The inspectors in other countries might do so as well.

FAQs

It is likely that the export regulations would not require that you maintain effective control of the computer and memory, according to the guidance given above.

You might need to maintain effective control over the device with GPS capabilities. If you do not feel you can maintain effective control, you should seek advice as noted above.

The export regulations likely would not require that you maintain effective control over them, but you should seek advice as noted in the first paragraph above in case there is an issue. You should not take with you any information or computer software received under an obligation of confidentiality or with restrictions on access by foreign nationals.

Questions?

Krista Campeau
Export Controls Officer
exportcontrols@umich.edu
(734) 615-0672