Laboratory personnel who participate in the procurement of materials, equipment, software, biologics, and other items can help facilitate understanding around export controls.
The simple use of most equipment on-site at BNL does not constitute a deemed export to foreign nationals. However, in-depth knowledge and responsibility for the maintenance, assembly, repair, construction of, or operation of equipment may constitute a “use” under export regulations that could require a deemed export license. Additionally, access to International Traffic in Arms Regulations (ITAR)-controlled equipment, i.e. equipment developed for a military purpose, requires access restrictions for all foreign nationals.
The equipment and materials purchased by BNL to support research activities may be subject to export control requirements. Foreign nationals are generally permitted to use Export Administration Regulations (EAR) controlled items on-site; however, transferring the technology or technical data about the controlled commodities to foreign nationals may require a license or license exception.