Issues to be considered when conducting research off Cornell's campus.

  • Be mindful of the Fundamental Research Exclusion.
  • Carefully review all consulting and other arrangements for terms that would render the research confidential or non-publishable (and therefore subject to export controls). Also look out for terms restricting participation or dissemination to citizens of certain countries.
  • Research conducted at an entity other than an accredited institution of higher learning in the U.S., and that is within the scope of the ITAR, cannot avail itself of the Fundamental Research Exclusion (and export controls will apply).

Outside the United States:

  • Any item shipped or hand-carried outside the U.S. needs to be assessed for export control compliance. Note that the Fundamental Research Exclusion does NOT apply to tangible materials.
  • Research in the scope of the ITAR is not fundamental when it takes place outside “accredited institutions of higher learning in the U.S.” 
  • Research in the scope of the EAR is not presumed to be fundamental as it would be if it was conducted at a university in the U.S., but still qualifies as fundamental as long as there are no restrictions on publication and participation.

Questions? Contact Cornell’s Export Control and Compliance Officer