Strategy and policies

As a world-leading institution engaged in research and knowledge exchange with partners across the globe, the University of Glasgow and its people must be alert to the possibility of our research and outputs being misused when exported.

UK export control refers to a set of legal restrictions on the transfer of certain goods, equipment, materials, software and technology from the UK to a destination or destinations outside the UK with the aim of protecting national security and preventing conflict, human rights abuse, weapons of mass destruction (WMD) proliferation and terrorism. Other reasons for controls include foreign policy and international treaty commitments (e.g. trade sanctions or arms embargoes).

The controls apply to the academic community (including individual members of staff, students, visiting researchers and contractors at the University of Glasgow) in the same way as any other organisation. If your work falls under the export control legislation, then a licence may be required.

It is important to note that export control regulations don’t only apply to the transfer of physical items but also to the transfer of information (including software, data, designs, knowledge or knowhow). Exports include:

• Physical exports (whether permanent or temporary e.g. material sent for analysis, use of a laptop outwith the UK which contains strategic technology);
• Electronic transfers (e.g. information in e-mail);
• Non-Electronic transfers (e.g. conversations, lectures, course notes); and
• Other transfers (including strategic goods and technology on a server which is accessible remotely e.g. accessing your e-mails and files stored on a UK server, whilst overseas and storing your files on non-UK servers).

Examples of relevant activities which may be covered by export control regulations include (but are not limited to):

• work for a commercial sponsor;
• research results circulated for colleague review or presented at an overseas conference;
• sending or taking physical items overseas;
• travelling overseas carrying information on a laptop, tablet, USB flash drive, portable hard drive or on paper;
• electronic transfer of information (e.g. via e-mail, text, social media, fax, virtual learning environments, file downloads, videoconferencing, sharing screens remotely, uploading information to an overseas server or uploading information to common and shared data environments);
• verbal transfer of information (e.g. in telephone or face-to-face discussions, including communication via platforms such as Zoom, Skype, Teams or FaceTime);
• staff or foreign students carrying sensitive research out of the UK or downloading it from a UK server while they are overseas;
• laboratory equipment or materials (even in very small quantities) exchanged with overseas collaborators;
• handling or transfers of certain equipment or technology from the US or equipment or technology containing US origin content;
• Online learning, Massive Open Online Courses (MOOCs);
• Patent applications

The Export Control Joint Unit (ECJU) administers the UK’s system of export controls and licensing for military and dual-use items.

Export Control Joint Unit website

Research  

There are areas of research where researchers should always take advice on Export Controls. Firstly, you should take particular care to check the export control requirements if your research has known or suspected utility in WMD or military end-use areas (including their development or procurement).

There are various research areas where items may be classified as dual use. If your research involves any of the following things, you should take particular care to check the export control requirements via the Goods Checker. Some examples include : 

End Use

In addition, we should consider our end user, and how any research could be used. Some points to consider regarding end use:

• Is the proposed end use credible considering the nature and specifications of the technology?
• Does the end use align with the end-user’s business or research goals?
• Do we know the intended end use? Or is the partner reluctant to offer information about the end-use of the items?
• Have unusual shipping, packaging or labelling arrangements been requested?
• Is the partner new to you and is your knowledge about them incomplete?
• Is the partner located in an area under strict security control or in an area to which access is severely restricted, or which is unusual in view of the type of equipment being installed?
• Are there unusual requirements for excessive confidentiality about final destinations, or customers, or specifications of items?
• Is the partner or end user a military or government research body?
• Is the partner or end user sponsored by a military or government research body?
• Is the project requested unusual in any way, e.g. the quantity or performance capabilities of the goods significantly exceed, without satisfactory explanation, the amount or performance normally required for the stated end use?

If you have any concerns related to any of the above please contact the Research Governance & Integrity team via the IT helpdesk

The University has developed an Export Control Policy and Compliance Procedure. It is the responsibility of all individuals, for example staff, students, visiting academics and contractors to familiarise themselves with this document.

To help determine whether export control restrictions apply to their work, individuals should refer to the flowchart in Annex 1 of the Export Control Policy and Compliance Procedure.

There will be some areas of research and collaboration where individuals should always take advice. If the research involves any ‘red flag’ areas (see Annex 2 of the Export Control Policy and Compliance Procedure). Individuals should take particular care to check the export control requirements.

If it is determined that export controls apply to your work, this does not mean that you will be prevented from continuing with your project/activity, it means that you will be required to apply for a licence from the ECJU, with support from the University’s Research Governance and Integrity Team. If you think export control requirements might apply to your work please e-mail compliance-support@glasgow.ac.uk.

The UK Government has produced useful guidance on how the UK’s strategic export controls apply to academics, university researchers and their institutions, and when an export licence is needed.

Information about export control lists and exemptions

The Export Control Joint Unit (ECJU) administers the UK’s system of export controls and licensing for military and dual-use items. Export Control lists are regularly updated by the Government.

Export Control Joint Unit website 

Most recent Export Control lists and a tool to search the database on the Gov.UK website

Categories of controls

The laws around export control focus on two main areas:

Military Items

Items with a specific military application fall into this category. Some examples might include radar antennae and weapon-locating systems, thermal imaging devices, target acquisition and tracking systems. This is not an exhaustive list.

Dual-Use Items

Items with a legitimate civilian use and which also have a military application fall into this category. Some examples might include dual-use parts and materials for nuclear reactors, chemicals, micro-organisms & toxins, navigation and avionics, unmanned aerial vehicles and associated technology;

However:

End-Use Controls

Where goods are not listed on the Export Control lists above, there may still be a requirement for a licence under the End-Use Controls. This will apply if the goods might have an end-use that could be for:

• Military purposes by a country subject to sanctions;
• WMD or in connection with WMD

Exemptions

There are certain exemptions that may be applicable to exports of controlled items. These cover:

• Information already in the public domain – e.g. freely available, such as in a book, on a website, etc;
• Basic scientific research – defined as: “experimental or theoretical work undertaken principally to acquire knowledge of the fundamental principles or phenomena or observable facts and not primarily directed towards a specific practical aim or objective”.

These exemptions do not apply however in cases where the proposed export is subject to the End-Use Controls. If you have been informed, or are aware of or suspect WMD or military end-use, then the item is still controlled and a licence may be required for export.

All individuals, for example staff, students, visiting academics and contractors, engaged in relevant disciplines have obligations and responsibility to ensure legal compliance with export control legislation.

Non-compliance with export control can result in very significant financial penalties for both the University and individuals themselves and is a serious criminal offence with custodial sentences of up to 10 years.

Principal investigators (PIs) are responsible for understanding export controls as they apply to their research. The principal investigator is responsible for ensuring that members of their team understand and comply with export controls.

Researchers and professional staff (particularly those working in science and engineering disciplines) should therefore ensure that they:

• Have read and understood the University’s Export Controls Policy and Compliance Procedure and the associated guidance on the University website;
• Have awareness as to whether their research area/s may be subject to export control legislation;
• Do not engage in any project activity for which an export control licence is required without first confirming that a licence has been obtained for that activity; and
• Seek advice from the University’s Research Governance and Integrity Team (E-mail: compliance-support@glasgow.ac.uk) if they suspect that export controls may apply to their work.

In some cases, it may be necessary to apply for an export licence from the UK Export Control Organisation to carry out an activity related to your research.

How to apply for an export control licence?

There are two categories of licence that you are most likely to require: 

• Open general export licences (OGELs) 
• Standard individual export licences (SIELs)

The Research Governance and Integrity Team can advise which is most appropriate for you and help with submitting the application. Please contact us via the IT Helpdesk just search for 'Research Governance and Integrity'.

Applying for a licence

All applications for open general export licences, or standard individual export licences are submitted via the Export Control Joint Unit's (ECJU) online export licensing system.

The RGIT will submit this application on your behalf, but will ask you for information including:

• the 'Control List entry' from the Goods Checker
• details of your partner and your export
• for a SIEL, an end-user undertaking form to accompany your application.

Download an End-user undertaking form

University policies 

• University of Glasgow Export Control Compliance Statement
• Export Control and Sanctions Policy and Compliance Procedure

Useful links

• Export controls applying to academic research
• OGEL and Goods Checker Tools
• Export Control Joint Unit (ECJU) 
• Guidance on exporting military or dual-use technology: definitions and scope 
• The UK Sanctions List 

Need help?

For further guidance on export control, please contact the University’s Research Governance and Integrity Team