Purchase of Research Equipment, Materials, Software & Technology
Overview
Researchers routinely purchase equipment, instruments, materials, chemicals, biological materials, software, technology, data, and other research assets to support University research activities.
Although most research purchases do not require additional review, certain items may be subject to U.S. export control regulations, federal sponsor requirements, research security considerations, or other institutional requirements. The Office of Research Security (ORS) assists researchers in identifying these requirements before purchases are completed.
REQUEST AN EXPORT CONTROL REVIEW
Contact ORS Before You
Contact ORS before you:
- Purchase equipment, software, technology, materials, or other items that may be export controlled.
- Purchase items designed for military, defense, aerospace, satellite, or other sensitive applications.
- Purchase equipment or software that restricts access based on citizenship or nationality.
- Purchase items that require end-use statements, export control certifications, or other compliance documentation.
- Purchase equipment or software subject to sponsor, contractual, or government restrictions.
- Purchase items from an unfamiliar foreign supplier or manufacturer.
- Sign or certify an export-related document, including an end-use statement, end-user certificate, export certification, or similar agreement.
- Are uncertain whether export control, research security, sponsor, or other institutional requirements apply.
Key Considerations
Some research equipment, materials, software, and technology are subject to U.S. export control regulations.
Manufacturers and vendors are generally the best source for export classification information, including Export Control Classification Numbers (ECCNs) and U.S. Munitions List (USML) designations. When purchasing research equipment, researchers should request the export classification, if available.
The export classification helps determine whether restrictions apply to the item's use, storage, access, transfer, or export. If classification information is unavailable or unclear, ORS can assist in determining the applicable export control classification and requirements.
Researchers are not expected to determine whether an item is export controlled. However, the following may indicate that additional review is appropriate:
- The vendor requests an end-use statement, end-user certificate, or export certification.
- Purchase documentation references the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), or other export control regulations.
- The vendor provides an ECCN or U.S. Munitions List (USML) designation.
- The vendor restricts sales based on citizenship, nationality, destination, or end use.
- The item is marketed for military, defense, aerospace, satellite, nuclear, or other sensitive applications.
- The purchase includes restrictions on access, use, transfer, or re-export.
Some purchased equipment, software, or technology may be subject to restrictions on release or access by foreign persons within the United States. Depending on the export classification and applicable regulations, additional safeguards, export control review, or a Technology Control Plan (TCP) may be required before controlled technology or technical information is released.
Research equipment and materials are often shipped internationally, hand-carried during travel, or shared with collaborators outside the United States after purchase.
If a purchased item will later be transferred internationally, additional export control review may be required depending on the destination, recipient, export classification, and applicable regulations.
Purchases involving foreign manufacturers, suppliers, or distributors may require Restricted Entity Screening to determine whether an organization appears on U.S. government restricted party lists.
ORS conducts screening when appropriate as part of its export control review.
Some federally sponsored research projects and research agreements establish requirements affecting the purchase, use, storage, transfer, or access to research equipment, software, technology, or other research assets.
ORS can assist investigators in identifying sponsor-specific or contractual requirements before purchases are finalized.
Some vendors require purchasers to complete end-use statements, end-user certificates, export certifications, or other export-related documentation before an item can be purchased or shipped.
These documents may include certifications regarding:
- The intended end use of the item
- The end user or recipient
- Export or re-export restrictions
- Military or prohibited end uses
- Compliance with U.S. export control regulations
Researchers should not sign export-related certifications on behalf of the University without institutional review. Forward these documents to ORS for review. ORS will determine whether the certification is appropriate, coordinate with Procurement and other University offices as needed, and execute export-related end-use agreements when required.
Related Guidance
| Related Guidance | Description |
|---|---|
| Export Control Classification | Learn how equipment, materials, software, technology, and technical information are classified under U.S. export control regulations. |
| Technology Control Plans | Guidance regarding safeguards that may be required for export-controlled research, equipment, software, or technical information. |
| International Transfers (Shipments, Hand-Carry & Electronic Transmissions) | Guidance for shipping, mailing, hand-carrying, or electronically transferring research equipment, materials, software, technology, technical information, or research information internationally. |
| Foreign Person Participating in Research | Guidance for employing foreign national faculty, staff, postdoctoral researchers, and students participating in research activities. |
| Deemed Exports | Learn when releasing controlled technology or source code to a foreign person within the United States may constitute a deemed export. |
| Restricted Entity Screening | Learn how organizations and individuals are screened against U.S. government restricted party and entity lists before certain research activities. |
Frequently Asked Questions
Do all research purchases require export control review?
No. Most research purchases do not require export control review. However, certain equipment, software, technology, materials, suppliers, or research projects may require additional review based on export control regulations, sponsor requirements, or other institutional considerations.
Should I ask the vendor for the export classification?
Yes. Manufacturers and vendors are generally the best source for export classification information. ORS can assist if classification information is unavailable or if additional review is needed.
The vendor asked me to complete an end-use statement or export certification. What should I do?
Some vendors require export-related certifications before completing the sale of export-controlled equipment, software, or technology.
Do not sign these documents on behalf of the University. Forward the request to ORS for review. ORS will determine whether the certification is appropriate, coordinate with Procurement and other University offices as needed, and execute export-related end-use agreements when required.
Can foreign persons use export-controlled equipment?
Possibly. Access depends on the export classification of the item, the applicable regulations, the research activity, and the type of controlled technology or technical information that would be released or accessed. ORS can determine whether additional safeguards, a Technology Control Plan, or other authorization is required.
When should I contact ORS?
Contact ORS before purchasing research equipment, materials, software, technology, or other research assets whenever you are uncertain whether export control, sponsor, research security, or other institutional requirements apply.
Need Assistance?
Contact ORS when a proposed research purchase may involve export-controlled items, foreign person access restrictions, vendor certifications, restricted suppliers, sponsor requirements, or other research security-related considerations. Early consultation helps identify applicable requirements before the purchase is completed.