Know Before You Go
Know that taking or sending abroad any equipment, samples, prototypes, research technical data, laptops, GPS, etc. is considered an export under U.S. law.
- Stay safe and up to date: Contact the Office of Research Protections and Compliance (ORPC) for information about countries you will be travelling to or through.
- Don’t travel with UMBC items, technology or unpublished technical data to foreign countries without contacting the ORPC for an export control review. Be sure to obtain departmental authorization using the UMBC Off Campus Equipment Loan Form while making travel arrangement. Include a copy the approval document with your certificate letter.
- If you don’t need it, don’t take it with you. Consider taking a clean laptop or flash drive or similar with information you need instead of taking a device that may contain technical or sensitive information, (unpublished research data, personal information, etc.).
- Do not travel to or through embargoed countries: Iran, Syria, Sudan, North Korea or Cuba without a license.
- Keep all items and technical data under your effective control at all times when outside of the United States.
- Be aware of any software or hardware you may carry with you that may contain encryption (laptops, PDAs, GPS, etc.). Contact the ORPC to know the export encryption related rules and exception criteria.
- Do not take any data or items with you that you cannot afford to lose or have seized.
- Any research data that is transported internationally must be approved by the data owner, via an approved data use agreement (DUA), a sponsored research agreement, data security plan, etc.
Abstracted from and courtesy of Carnegie Mellon University – Office of Research Integrity and Compliance – Foreign Travel: Know Before You Go
Tools of the Trade: Traveler Certification Letter
The ORPC has created the below “Tools of the Trade” Traveler Certification Letter for international travelers carrying university-owned equipment or research data to confirm and certify that they meet the requirements of the exemption. The letter serves as a document that can be carried with the traveler and shown to US or foreign customs agents in the event that they are questioned about the content of their belongings. While there is no way to guarantee that the letter will prevent searches and seizures, it may demonstrate that the traveler is familiar with the regulations and responsible for the equipment that they are exporting.
Background: Once you depart the US, regardless of your mode of travel, all hand-carried items are considered to have been “exported” from the US and subject to US export regulations. Travelers are personally responsible for ensuring that the items and data they are carrying are legally exported and that you have appropriate university approval to their travel destination. The Department of Commerce’s Export Administration Regulations (EAR) makes an exception to licensing requirements (15 CFR 740.9) for the temporary export or re-export of certain items, technology, or software for professional use as long as the criteria to which you are certifying below are met. Please contact the ORPC with any questions.
Items Eligible for TMP Exemption
Tools of the trade: UMBC-owned laptops, tablets, smart-phones and other electronic storage media necessary and related to the purpose of the travels. Please note if you plan to take personally-owned computers, devices or phones while traveling, you are responsible for properly securing them. These devices can contain personal and private information, such as notes, photos, contacts, saved passwords, etc. If you don’t need to take them and can’t afford to lose them, leave at home.
Items NOT Eligible for Exemption
Items, technology, data, or software designed for military or dual-use purposes. Satellite or space-related equipment, components, or software, or any technology associated with high-level encryption products.
Instructions: Review, complete the highlighted sections of the certification letter and sign/date. Email a scanned version to the Office of Research Protections and Compliance to email@example.com at least five (5) business days before your scheduled trip. Once reviewed and signed by the ORPC, a copy will be returned to you to carry with your luggage to present to Customs if requested or in the event of a search. Include a copy the equipment loan approval document with your certificate letter. The Kuali data use agreement (DUA) number will assist the ORPC with tracking the travel request to the DUA.
Contact the ORPC anytime with any questions or concerns, or if you run into problems while abroad at firstname.lastname@example.org
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