Examples
Worked examples
- Is an instance
A defence-funded project with publication restrictions and citizenship requirements is treated as export-controlled.
- Is an instance
Transfer of specific encryption source code to a non-US national requires an export licence determination.
Counter-examples
Looks similar, but isn't
- Not an instance
Open published research findings derived from non-controlled work do not constitute an export-controlled item.
- Not an instance
Coursework using publicly available textbooks is not export-controlled.
Editorial commentary
Export-controlled research is research, data, software, or physical items subject to US government regulations restricting transfer to foreign persons, foreign destinations, or certain end uses — regardless of whether the transfer happens by shipping something overseas or simply by allowing a foreign national to see, hear, or use it while standing in a US laboratory. Two regulatory regimes cover most cases: the International Traffic in Arms Regulations (ITAR), administered by the State Department’s Directorate of Defense Trade Controls and covering defense articles on the US Munitions List, and the Export Administration Regulations (EAR), administered by Commerce’s Bureau of Industry and Security and covering dual-use items on the Commerce Control List.
The fundamental research exclusion
Most US university research is not export-controlled in practice because of the fundamental research exclusion rooted in National Security Decision Directive 189 (NSDD-189): basic and applied research intended for open, unrestricted publication is generally outside ITAR/EAR jurisdiction, even if the underlying subject matter would otherwise be controlled. That exclusion is lost when a project accepts publication restrictions, nationality-based access limits, or certain proprietary or classified obligations from a sponsor — at that point the work must be classified for export-control purposes like any other controlled activity.
When a project is controlled, two mechanisms typically follow: a jurisdictional determination by the institution’s export control office or Empowered Official, and — if a foreign national will have access to the controlled item or data — a Technology Control Plan to manage that access, since granting it is treated as a deemed export to the individual’s country of citizenship even with no physical shipment involved. See ITAR vs. EAR for how the two regimes differ in scope and licensing agency, and ITAR and EAR compliance for university research for the institutional process end to end. Export-controlled research is distinct from the broader research-security disclosure obligations covered elsewhere in this family — a project can be fully disclosed under Current and Pending Support and still separately require export-control review if it involves controlled technology.
Also known as
export-controlled project · ITAR/EAR research
Machine-readable encodings
Use in your systems
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vocab-identifier="https://casrai.org/dictionary/"
vocab-term="Export-controlled research"
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"datePublished": "2026-05-21T02:22:53",
"dateModified": "2026-08-22T16:26:27",
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