The controlled technologies most commonly found on campus are “dual-use” technologies covered by the Export Administration Regulations (EAR). These are items or technologies with potential for both civilian and military use (the military use may not be obvious). Dual-use items can be found on the Commerce Control List (CCL). Each category on the CCL is assigned an Export Control Classification Numbers (ECCNs).
Commerce Control List – Dual-Use Item Categories (EAR)
• Category 0 Nuclear Materials, Facilities and Miscellaneous
• Category 1 Materials, Chemicals, Microorganisms, and Toxins
• Category 2 Materials Processing
• Category 3 Electronics
• Category 4 Computers
• Category 5 Part 1: Telecommunications Part 2: Information Security
• Category 6 Lasers and Sensors
• Category 7 Navigation and Avionics
• Category 8 Marine
• Category 9 Propulsion Systems, Space Vehicles, and Related
Each CCL Category is subdivided into five (5) Groups: (A) Equipment, assemblies, and components; (B) Test, inspection and production equipment; (C) Materials; (D) Software; and (E) Technology.
Military technologies are regulated under the International Traffic in Arms Regulations (ITAR) and are listed on the United States Munitions List (USML).
- Category I-Firearms, Close Assault Weapons and Combat Shotguns
- Category II-Guns and Armament
- Category III-Ammunition/Ordnance
- Category IV-Launch Vehicles, Guided & Ballistic Missiles, Rockets, Torpedoes, Bombs and Mines
- Category V-Explosives and Energetic Materials, Propellants, Incendiary Agents and Constituents
- Category VI-Surface Vessels of War and Special Naval Equipment
- Category VII-Ground Vehicles
- Category VIII-Aircraft and Related Articles
- Category IX-Military Training Equipment and Training
- Category X-Protective Personnel Equipment and Shelters
- Category XI-Military Electronics
- Category XII-Fire Control, Range Finder, Optical and Guidance and Control Equipment
- Category XIII-Materials and Miscellaneous Articles
- Category XIV-Toxicological Agents, including Chemical and Biological Agents, Associated Equipment
- Category XV-Spacecraft Systems and Associated Equipment
- Category XVI-Nuclear Weapons Design and Testing Related Items
- Category XVII-Classified Articles, Technical Data and Defense Services Not Otherwise Enumerated
- Category XVIII-Directed Energy Weapons
- Category XIX-Gas Turbine Engines and Associated Equipment
- Category XX-Submersible Vessels and Related Articles
- Category XXI-Articles, Technical Data, and Defense Services Not Otherwise Enumerated
Investigators should be aware that equipment and technologies designed for military use controlled by the ITAR will require a license for export or foreign national access even if being used for non-military purposes in a U.S. laboratory. For example, ITAR controlled night vision equipment in use on campus to visualize cells under infrared light for biomedical research will require a license from the Department of State for access by foreign nationals (including students and postdoctoral fellows).
For assistance in determining if your technology is controlled under the EAR or the ITAR, please contact the Export Control Manager at OVCRExportCompliance@wustl.edu. If you have foreign collaborations or would like to have foreign nationals on projects with controlled technologies, you may need to obtain a license prior to commencement of work.
Important note about Biological and Chemical Agents
Unlike the EAR, which maintains a specific list of controlled biological items, ITAR-controlled biological and chemical agents are more broadly defined as “substances capable of producing casualties in humans or livestock, degrading equipment or damaging crops and which have been modified for the specific purpose of increasing such effects.” Medical remediation methods, vaccines, antitoxins, antibodies, diagnostics, software and technical data relating to such agents may also be controlled. If you are working with agents that fit this definition, please contact the Export Control Manager at firstname.lastname@example.org.