International Travel

When traveling abroad there are three basic questions that university personnel need to consider when determining if export controls apply to their travel:

Where are you going?

In general, travel to most countries is not a problem. Tighter export controls are in effect for countries that are comprehensively sanctioned or have restrictions on trade enforced by various departments of the U.S. government. The following, most comprehensively-sanctioned countries will require advance planning and coordination with our Export Control office: Cuba, Iran, North Korea, Sudan, Syria, and Crimea Region of the Ukraine. Contact the Export Control Officer as soon as you anticipate travel to one of these countries. 

When traveling abroad, it is always a good idea to contact the appropriate U.S. Embassy or Consulate before you depart. We strongly advise that you regularly check the State Departments alert/warning website for updates.  To register your travel plans with an embassy and receive helpful safety and emergency information related to your destination, visit the Department of State’s Smart Traveler Enrollment Program. For more information about U.S. Embassies and Consular Offices visit USEmbassy.gov.

What are you taking with you?

Items & Equipment

When taking items abroad (including scientific equipment, laptops, encryption software, cell phones, tablets, flash drives, cameras, and GPS units), you need to verify that the items are not export restricted based on your travel destination(s). When transiting between countries you may be asked to provide an Export Control Classification Number (ECCN) for each item you take.

Please refer to the chart below for the ECCNs for equipment most commonly taken abroad. If you are planning to take equipment that is not listed in the chart below, please contact the Export Control Officer to obtain the ECCNs for your specific item(s).

Most commercially available basic software (such as Microsoft Office) is EAR99 and can be exported either individually or on your device without a license.   However, proprietary software, software that includes encryption, and/or other complex software may require an export license and should be reviewed by the Export Compliance Office.  Please contact the Export Control Officer if your device includes any of the above software.

ECCNs for Common Travel Items*

*Do NOT use this chart for travel to Cuba, Iran, Sudan, Syria, North Korea, or Crimea Region of the Ukraine

ITEM
ECCN#
LICENSED AUTHORITY
Dell Laptop (no encryption)
4A994
No Licensed Required (NLR)
Mac Laptop
5A992
No Licensed Required (NLR)
IPhones & IPads
5A992
No Licensed Required (NLR)
Jump/Flash Drive (most)
3A991
No Licensed Required (NLR)
Android Cell Phone/Tablets
5A992
No Licensed Required (NLR)
Garmin GPS
7A994
No Licensed Required (NLR)
Bitlocker Encryption
5D992
No Licensed Required (NLR)
GoPro Camera
EAR99
No Licensed Required (NLR)

If you are traveling with items to Cuba, Iran, Syria, Sudan and North Korea, or providing access to your items to a citizen of one of those countries, an export license will most likely be required. Contact the Export Control Officer for help in determining your export license requirements.

What other things should I consider when traveling with research and other equipment abroad?

  • Do you have proper insurance against loss, damage, or theft?

In general, the University has a property insurance policy that includes coverage for University owned property (buildings and contents) in the event of insurable events such as fire, flood, vandalism, and theft. Property insurance provides coverage for sudden and accidental losses. However, when taking University equipment outside the U.S., you must contact the Office of Purchasing and Insurance to ensure that appropriate insurance coverage is in place in case of loss, theft, or damage while abroad.

  • Avoid potential duty and import tax payments when taking research equipment temporarily abroad

You may want to consider registering your items or equipment prior to traveling. For personal items use Customs and Border Protection (CBP) Form 4457; for commercial or professional items use CBP Form 4455. Both forms are used to register the items prior to the temporary export. The purpose of the forms is to demonstrate, upon re-entering the U.S., that you had the items before leaving the U.S. and, therefore, allows a duty-free re-entry back to the U.S. For more information on registering your items with CBP, please see here. Please note, however, that CBP Forms 4457 and 4455, are not acceptable temporary import documents to avoid import duty and tax into foreign countries.

If you are traveling with special research equipment and want to avoid both, potential import duty and tax payments when entering the foreign country and when re-entering the U.S., you may want to consider using a Carnet.

What is a Carnet?

A Carnet is an international customs document that facilitates temporary (up to one year) imports into foreign countries. There are some 87 countries that participate in the Carnet program (also referred to as “carnet countries”). When presenting the Carnet to foreign customs, you will not be charged duties or import taxes. The Carnet also serves as a registration of goods in the U.S., which further facilitates the re-importation into the U.S. without having to pay import duties.

Carnet Costs

The cost of a Carnet is typically determined by the value of the equipment that is shipped or taken abroad. Basic processing fees range between $225 and $380.

For more information on Carnets and how to obtain them, please see the ATA Carnet website.

Research Data & Information

You are free to take and openly discuss any data or information that is published, in the public domain, is normally taught as part of a class or that resulted from Fundamental Research. However, you cannot take or share data or information that is in any way export-restricted, such as information about export-controlled technologies, proprietary information, or the results of a project not protected under the Fundamental Research Exclusion. Sharing these types of information may constitute an unauthorized export.

You should plan to travel with “clean” electronic devices, such as your laptop , smart phone, electronic storage media, etc.  This means that your electronic devices should not contain any export-controlled information or restricted data and information should be completely removed from laptops, phones, PDAs, or other portable storage devices (e.g., flash drives) before you leave the U.S. Please remember that it is violation of U.S. export regulations to take export-controlled technical data (controlled information) out of the U.S. without a U.S. export control license or applicable exemption, even if you do not share it with anyone while you are abroad.

Brown's IT Group has prepared useful tips for international travelers that can be found here and here. Brown's IT Group also has an international device loaner program with a limited amount of clean travel laptops (PCs and MACs). If you have any interest in this program, please contact Juliane Blyth.

What will you be doing and who will you be interacting with?

It is important to ensure that you do not accidentally export restricted information or provide any type of assistance or benefit to a sanctioned or blocked entity (Restricted Party). The following are a few things to keep in mind as you plan your travel activities:

Presentations

When presenting data/information in an international setting (including in the U.S. where the audience may include foreign nationals), you need to ensure that you limit your presentation to only information or data that is published, or is publicly available, or that qualifies as Fundamental Research. Be careful not to include or discuss any proprietary, unpublished, or export-restricted data or information as that may constitute an unauthorized export.

Interactions with Foreign Colleagues

As noted above, you are free to openly discuss any published or publicly available information or information generated as the result of Fundamental Research as long as the recipient is not a sanctioned or specially designated entity. It is important to remember that while the results/information resulting from Fundamental Research are not subject to export controls and can be shared without a license, any items, technology, or software generated under that Fundamental Research would be subject to export controls and may require an export license.

Field Work

Any university research activity done outside the U.S. may not qualify for the Fundamental Research Exclusion. Before disclosing or sharing information or data resulting from international field work it is important to ensure that the information is not export restricted.

In addition, please contact the Export Control Officer as soon as possible if any of the following factors are involved with your research:

  • Taking equipment other than items listed in the ECCN chart above;
  • Planning to bring back samples;
  • Sending equipment, materials, or information from the U.S. to a foreign destination; or
  • Potential or existing non-disclosure agreements or restrictions on the publication of research results.

To help ensure smooth international travel and compliance, contact Brown’s Export Control Officer as soon as possible if you have questions or concerns about export controls as they may apply to your travel plans.