It is important to think about export controls when traveling internationally. If you are traveling with ITAR-controlled data, this is considered to be an export, just as it would be if you were sending data overseas electronically. Similarly, hand-carrying EAR-controlled equipment or data may require an export license.
Note: License exceptions may be available when Princeton-affiliated individuals plan to take University-owned or personal items out of the country.
Travel to countries subject to United States government sanctions (i.e. Cuba, Iran, North Korea and Syria) may require prior United States government authorization. This includes travel for purposes that would not otherwise be subject to United States export control laws, such as participation in a conference.
Contact the Vice Provost for International Affairs and Operations for travel to all sanctioned countries and for detailed information about Princeton's initiatives in Cuba.
United States persons are prohibited from engaging in activities with individuals that have been determined to be acting contrary to the interests of the United States, also known as restricted parties. In addition, United States persons are prohibited from engaging in financial transactions with certain individuals and entities.
Before traveling to a foreign country, you should request a screening of any known contacts against restricted party lists. The screening takes only minutes and can be performed by your ORPA administrator.
Many travelers do not realize that traveling overseas commonly involves the “export" of equipment and technology. For example, traveling overseas with your equipment, laptop, or cell phone is considered to be an export of the equipment, even though it will likely qualify for an exemption.
Of particular concern from an export controls perspective is the export of military or space-related data subject to ITAR regulations. The export of such technical data or software, even if it is simply on a laptop taken out of the country, requires a license. Confidential or proprietary data (such as that provided by a sponsor) may also require an export license under the EAR if it is shared with non-U.S. persons.
The majority of exchanges between researchers off-campus can go forward without an export license. When in doubt, stick to information that is in the public domain or intended to be published. International conferences which are limited to published or publishable research are covered by the "publicly available/public domain" exclusions provided by the regulations. No export license is needed when these conference discussions take place.
However, there are two exceptions to this rule which may require an export license:
If you are exporting equipment or data, even by hand, the export or data should be reviewed for compliance with export control regulations. In many cases, such exports may qualify for one of the exceptions to export control regulations. In other situations, an export license may be required, often depending upon the specific item and destination. Contact the Assistant Director of Export Controls for assistance.
United States law prohibits the export, re-export, and certain transfers of equipment or technical data related to the following:
The following recommendations apply to all international travel by the Princeton community.
All confidential or proprietary information should be removed from your laptop, cell phone, and other electronic devices prior to travel. Clean "loaner laptops" may be available in some departments. To learn more, review OIT's International Travel Guidelines.
You must remove information or data provided by U.S. Department of Defense agencies (AFRL, ONR, DARPA, AFOSR, etc.) prior to departure. Simply leaving the U.S. with such data, unless licensed by the U.S. government, is a violation of U.S. export control regulations.
You may be able to minimize or eliminate duties and taxes related to the import or export of equipment or commodities in some cases, including by using an ATA Carnet. Adequate time must be provided in order to investigate the options and obtain proper documentation.
Each country has its own import and export requirements. Just because a piece of equipment does not require a U.S. export license does not mean it will not require an import permit for entry into another country.
The following resources are available to assist you prior to travel:
Depending on the country to which you are traveling, there may concerns with the type(s) of encryption software on your devices. Because encryption products can be used for illegal purposes, including terrorist activity, the U.S. and many other countries may ban or severely regulate the import, export, and use of encryption products.
Moreover, taking a laptop with encryption software to certain countries without proper authorization could violate U.S. export control laws or the import regulations of the country to which you are traveling. This could result in confiscation, fines, or other penalties.
Princeton's Office of Information Technology provides information about what software is permitted and what countries may be of concern. Review this information prior to traveling abroad.
