Scholars often engage in research activities that require the export of a commodity either as an input into the activity or an outcome of the research activity. Although JMU-generated information is covered by the "fundamental research exclusion," its tangible products (hardware, software on media, equipment, components, etc.) are not. For this reason, international tangible exports (whether software, technology, or a chemistry beaker) must be reviewed for export control. The following steps will help to document due diligence in making tangible export shipments (whether hand-carried or vendor shipped).
Step 1: Training
Whether required by your sponsored research donor or your own expectation that your research may lead to tangible exports as an input or output of your international activity, you are expected to receive appropriate training. JMU offers online training through the Collaborative Institutional Training Initiative (CITI). The CITI Export Control Training Instructions will facilitate the start of your training and that experience will support your next steps in determining whether your activity is subject to export control regulations.
Step 2: Sponsored Research Export Control Decision Tree
The principal investigator in a sponsored research program must determine whether they will export tangible inputs or outputs associated with a research activity. JMU provides an export control decision tree and IRES also is available to assist you in completing the evaluation on whether your activity is subject to export control regulations.
Step 3: Contact IRES
Contact IRES (IRES@jmu.edu) if you believe the item is on an export control list or if you are seeking IRES assistance in making the classification decision.
Step 4: Screen your recipient
While the export decision tree for sponsored research provides a mechanism to identify export control concerns based on the country or citizenship of the recipient of a tangible export, the researcher should also identify whether the recipient or associated organization (when applicable) are listed on U.S. export control restricted party lists (link to screening instructions page).
