If traveling with any research equipment, research kits, or other items, including laptops, owned by Brown University, you must contact the Export Control team prior to departure. However, if you are traveling with only your personal items, including personally owned laptops, you do not need to contact Export Control.
Division of Research
U.S. Export and Transfer Restrictions
China, Hong Kong, Burma, Cambodia and Venezuela
Export Administration Regulations require that Electronic Export Information (EEI) is filed for all items listed on the Commerce Control List (CCL) that are exported to China, Hong Kong, Burma, Cambodia or Venezuela, regardless of value. In order to fulfill this requirement, the exporter must know and provide the correct Export Control Classification Number (ECCN) of the item that is being exported or confirm that the item is classified as EAR99.
If you need assistance in determining an item’s ECCN, you can reach out to the manufacturer or vendor of the item. If the export is related to research, you may also contact Brown’s Export Control team for assistance
Failing to file an EEI for items listed on the CCL or providing false export control classification information to shippers or freight forwarders is a violation of export regulations and can result in civil and criminal penalties.
Review of End-User/End-Use Certification
If the item you are exporting to China, Hong Kong, Burma, Cambodia or Venezuela has any of the ECCNs listed below, you must contact Export Control for end-user/end-use verification and review. Items with these ECCNs cannot be exported to a military end-user or for military end-use in these locations without a license from the U.S. Department of Commerce.
- Category 1
- Materials, Chemicals, Microorganisms, Toxins: 1A290, 1C990, 1C996, 1D993, 1D999, 1E994
- Category 2
- Materials Processing: 2A290, 2A291, 2A991, 2B991, 2B992, 2B996, 2B999, 2D290
- Category 3
- Electronic Design, Development and Production: 3A991, 3A992, 3A999, 3B991, 3B992, 3C992, 3D991, 3E991
- Category 4
- Computers: 4A994, 4D993, 4D994
- Category 5
- Telecommunication and Information Security: 5A991, 5B991, 5D991, 5E991, 5A992, 5D992
- Category 6
- Sensors and Lasers: 6A991, 6A993, 6A995, 6A996, 6C992
- Category 7
- Navigation and Avionics: 7A994, 7B994, 7D994, 7E994
- Category 8
- Marine: 8A992, 8D992, 8E992
- Category 9
- Propulsion Systems, Space Vehicles and Related Equipment: 9A991, 9B990, 9D991, 9E991
Russia and Belarus
In late February and early March 2022, the U.S. government imposed new economic sanctions and export controls on Russia and Belarus. Brown faculty, researchers, staff and students who send or hand-carry (export) any item permanently or temporarily, including documents and materials, to Russia or Belarus must comply with new requirements. Failure to comply is considered a violation of export control and sanctions regulations and may result in civil and criminal penalties.
In May 2023 the U.S.government expanded the scope of its sanctions on Russia and Belarus to include a variety of new items, including electronics, instruments and advanced fibers for the reinforcement of composite materials, including carbon fibers. The rule also extends to the occupied Crimea region of Ukraine.
Export Control Classification
Brown personnel who ship or hand-carry items to Russia or Belarus must know the item’s Export Control Classification Number (ECCN) and receive confirmation that the item does not require a license. If you need assistance in determining an item’s ECCN, you can reach out to the manufacturer or vendor of the item. If the export is related to an item or product that you developed in your research, you may also contact Brown Export Control for assistance.
All items that carry an ECCN in the categories 1 through 9 of the Commerce Control List, as well as some items with EAR99 classification, require a license from the U.S. Department of Commerce Bureau of Industry and Security (BIS). This includes microelectronics, telecommunications items, sensors, navigation equipment and aircraft components.
Please note that, according to BIS, applications for the export, re-export or transfer (in-country) of items that require a license for Russia or Belarus will be reviewed, with limited exceptions, under a policy of denial.
Commerce Control List Categories
- Category 1
- Materials, Chemicals, Microorganisms, Toxins (e.g., 1C351)
- Category 2
- Materials Processing (e.g., 2B991)
- Category 3
- Electronic Design, Development and Production (e.g., 3A991)
- Category 4
- Computers (e.g., 4A994)
- Category 5
- Telecommunication and Information Security (e.g., 5D991)
- Category 6
- Sensors and Lasers (e.g., 6A991)
- Category 7
- Navigation and Avionics (e.g., 7A994)
- Category 8
- Marine (e.g., 8D992)
- Category 9
- Propulsion Systems, Space Vehicles and Related Equipment (e.g. 9A515)
Commerce Control List (CCL) Index
Review of End-User/End-Use Certification
Items subject to Export Administration Regulations, including items classified as EAR99, cannot be exported to a military end-user or for military end-use in Russia or Belarus without a license from the Department of Commerce/BIS. The federal government requires that the exporting entity conduct and appropriately document a military end-use/end-user review for each proposed export. If you are sending or carrying to Russia or Belarus any item that is subject to regulation, you must contact Export Control for verification and review.
Restricted Foreign Universities
To assist researchers at Brown, the Export Control team provides the names of several degree-granting foreign institutions that are currently sanctioned by the U.S. government. Please note that these lists are not complete, and that the official lists are updated frequently; check the full list to ensure compliance with U.S. regulations.
Foreign Universities on the Entity List
The U.S. Department of Commerce Entity List includes businesses, research institutions, government and private organizations and individuals, and other types of legal persons that are subject to export and transfer restrictions. Research collaborations and the exchange of items or information with any listed institution, as well as visitors to Brown who are employed by, representatives of or affiliated with any listed institution, must be vetted by Export Control.
An export license is required for all items subject to Export Administration Regulations for the following restricted institutions (listed by country and with all known names).
| Country | Name of Degree-Granting Institution | Additional Names |
|---|---|---|
| China | 54th Research Institute of China | China Electronics Technology Group Corp. (CETC) 54th Research Institute |
| Communication, Telemetry and Telecontrol Research Institute (CTI) | ||
| Shijiazhuang Communication Observation and Control Technology Institute | ||
| China | Beijing Institute of Technology | |
| China | Beijing University of Posts and Telecommunications | |
| China | Beijing University of Aeronautics and Astronautics (BUAA) | Beihang University |
| China | Chinese Academy of Engineering Physics | Located in or near Mianyang, Sichuan Province:
|
| The High Power Laser Laboratory, Shanghai | ||
| The Institute of Applied Physics and Computational Mathematics, Beijing | ||
| 901 Institute | ||
| China | Harbin Engineering University | |
| China | Harbin Institute of Technology | |
| China | Hefei National Laboratory for Physical Sciences at Microscale | |
| China | Nanjing University of Aeronautics and Astronautics | |
| China | Nanjing University of Science and Technology | |
| China | National Supercomputing Center Guangzhou (NSCC-GZ) | Sun Yat-Sen University |
| China | National University of Defense Technology (NUDT) | |
| China | Northwestern Polytechnical University | Northwestern Polytechnic University |
| China | Sichuan University | |
| China | Tianjin University | |
| China | University of Electronic Science and Technology of China | |
| China | Xinjiang Police College | |
| Russia | Moscow Institute of Physics and Technology | |
| Syria | Higher Institute of Applied Science and Technology (HIAST) | Institut Supérieur des Sciences Appliquées et de Technologie (ISSAT) |
| Institut des Sciences Appliquées et de Technologie (ISAT) |
Foreign Universities on the Unverified List
The Unverified List is a precursor to the Department of Commerce Entity List. Parties are added to the Unverified List when there may not be sufficient information to add the foreign person/entity at issue to the Entity List. Parties listed on the Unverified List are ineligible to receive items subject to Export Administration Regulations by means of a license exception and there are additional filing and documentation requirements if items are transferred to a party on the list.
| Country | Name of Degree-Granting Institution |
|---|---|
| China | Anhui Institute of Metrology |
| China | Guangdong University of Technology |
| China | Hefei Institutes of Physical Science |
| China | Hunan University, State Key Lab of Chemo/Biosensing and Chemometrics |
| China | Nanchang University |
| China | Shanghai Institute of Applied Physics |
| China | Southern University of Science and Technology, Department of Mechanical and Energy Engineering |
| China | Sun Yat-Sen University |
Foreign Institutions on the Specially Designated Nationals List
As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups and entities, such as terrorists and narcotics traffickers, designated under programs that are not country-specific. Collectively, such individuals and entities are called Specially Designated Nationals. Their assets are blocked and U.S. persons are generally prohibited from dealing with them.
| Country | Name of Degree-Granting Institution |
|---|---|
| Iran | Baqiyatallah University of Medical Sciences |
| Iran | Imam Hossein University |
| Iran | Malek Ashtar University of Technology |