Export Controls and International Travel

International travel implicates export controls because anytime you leave the country, anything you take with you is an export.  This is true even if you maintain possession of the information or tangible items (e.g. you take a computer with you-the computer is being exported).  You must ensure that what you take with you has the appropriate license granted by the Federal government, or that the item or information falls within an appropriate license exception. 

Restrictions on items (information and tangible items)

It is your responsibility to ensure that you have the proper licenses (if any are required) for any of the items you take with you.  Further, you must ensure that your electronic devices do not contain any export-controlled information.  The ORA can assist you with determining whether your items/information are controlled.

Best practice is to remove information from your electronic device and only access it through a web browser.  Information technology provides additional guidance on both required practices for UA information and tangible items and best practices for your own security.

Travel Information and Policies

The University of Akron uses a travel registry for UA-based travel plans.  Please see the information at this link.

Further, Information Technology policy requires that employees planning to travel with a UA laptop must take a loaner, rather than their assigned computer.  For more information, please see this link.

Some Exceptions you may utilize

TMP Exception: The Department of Commerce allows some items to be exported to international locations, as long as the export will be used for professional purposes and the following apply:

• The item or information will remain in your "effective control;"
• The item or information will be exported temporarily (fewer than 12 months); and
• The item or information will be used only as a tool of the trade (for professional purposes).

You may not use this exception if the item or information is controlled by the ITAR regulations (e.g. military use), the items are space related, nuclear related, or contain high-level encryption technology.

BAG Exception: Personal items like clothes, medicine, personal products are generally permitted to be exported under the personal baggage exception, as long as these are intended for your own personnel use, and not as gifts to others.

Travel to Russia, Venezuela, or China

Although you may not need a license when hand-carrying items to these three countries, the Federal government requires that all items on the Commerce Control List (CCL), regardless of value, are declared prior to traveling with them to any of these three countries.  Note that computers, cell-phones, and typical commercially available electronics are on the CCL and must be declared.  The ORA can assist you for personal items.  It will complete the declaration (called an Electronic Export Information document) for any UA items being taken to these countries.  See 15 C.F.R. 758.1(b)(10) for more information.