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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 “Tools 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 "mass market" encryption, i.e., encryption of the kind that is generally available to the public and does not allow for user revisions to enhance communciations security capabilities. "Mass market" encryption software is either pre-installed on standard, off-the-shelf hardware or can be purchased and installed by a user without vendor support. Examples include: FileVault for Mac, Bitlocker for Windows, U-M Cisco VPN, and Duo.

  • 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:  The Duo app and hardware tokens (Duo) are encryption items subject to U.S. export control regulations. Generally, you may travel with Duo and ship it internationally, except to a few countries. Duo is controlled as follows:

Shipping Duo:

You may ship Duo internationally, except to Cuba, Iran, North Korea, Sudan, Syria and the Crimea region of Ukraine where you must first notify the U-M Export Control Program (exportcontrols@umich.edu) and obtain an export license. 

Traveling with Duo:

You may take Duo with you when traveling internationally, with the following restrictions:

* Cuba and Sudan - Duo may be taken to these countries using a "Tools of Trade" license exception.​

* ​​North Korea, Syria or the Crimea region of Ukraine - Duo may not be taken to these countries without a prior review by the U-M Export Control Program (exportcontrols@umich.edu). A determination will be made whether a license exception is available.

* Iran - Duo may not be taken to Iran under the "Tools of Trade" or any other license exception. No license exceptions apply to Iran. Please contact the U-M Export Control Program (exportcontrols@umich.edu) if you would like to discuss applying for a license to Iran.

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.