Licenses and License Exceptions

Who Can Apply for a License?

Only the designated empowered official may apply for a license.

Consultation with the Office of Research Compliance (ORC) should be made prior to shipping or sending any export controlled items, technical data, or technology internationally (including Canada) or sharing any export controlled technology or technical data with a foreign person in the U.S.

What Information is Required to Evaluate if a License is Required?

What is being shipped/shared?

What country? 

       If shipping/sharing outside of the U.S. - what is the destination country? 

       If sharing inside the U.S. with a foreign person - what is their home country?

Who is it being shipped to (person and entity)?

What is the intended use of the item?

How Long Does it Take to Receive a License?

Depending upon the details of the export transaction and the regulatory agency involved, licenses can take up to six months to receive. Licenses for activities to embargoes/sanctioned countries may take up to one year.

How About License Exceptions?

International Traffic in Arms Regulations (ITAR)

Under the ITAR, license exceptions are extremely limited and no item enumerated on the United States Munitions List should be exported without consultation with and approval from the Office of Research Compliance as a license is almost always required.

Export Administration Regulations (EAR)

Under the EAR, Section 740.1 through Section 740.20 a license exception is an authorization that allows you export or re-export under specific guidelines items subject to the EAR that would otherwise require a license. These license exceptions should not be used without consultation with and approval from the Office of Research Compliance as thorough documentation and record keeping is required.

A Cautionary Note Regarding License Exceptions

  • Not all license exceptions are applicable to all items on the EAR

  • Even if stipulated as a license exception for an item it may not be applicable for all destinations

  • All license exceptions need to be recorded as to how the determination of applicability was made

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