International Travelers

Any individual who travels for either personal reasons or ECU business, with an ECU-owned laptop or other university-owned equipment, should be aware of these basics:

  • Regardless of who will pay for travel expenses, if international travel supports an individual’s ECU-related role, the traveler (or designated travel preparer) must submit a travel request in ECU’s travel system.
  • If traveling for personal reasons with an ECU laptop or other equipment belonging to the University, notify OECC at ECUExportControls@ecu.edu with a list of equipment and destination country.
  • Almost all laptops, tablets, iPhones, Androids and similar devices are considered mass market encryption devices. While these items are subject to U.S. export controls, the devices, as well as installed mass market encryption software, typically do not require export licenses. Microsoft Office products, such as Outlook and Skype, are examples of mass market encryption software.
    • Some destination countries might require import licenses. While this is rare, check with us if you are uncertain. Quantity exemptions often exist.
    • Remember to comply with ECU policies regarding password and encryption protection in order to protect ECU data.
    • As a best practice, remove data unnecessary to your travel.
    • Technical data on your laptop must be evaluated for export controls separately from the laptop and software evaluations.
  • If you’re traveling with equipment, the physical movement to another country does constitute an export. It’s likely that the equipment either:
    • Requires no export license, or
    • Qualifies for what is known as a TMP – temporary export – license exception as a “Tool of Trade.”
      • TMP-eligible equipment that you take with you, either in the flight cabin or in checked luggage, does not require reporting
      • TMP-eligible equipment that you ship separately requires reporting or documentation demonstrating why the reporting was not required

A person boarding a plane

International Traveler Questions

Question 1: What is required of me if I am only temporarily removing ECU-owned equipment from the U.S.?

You must notify the ECU Office of Export Controls and Customs. You might also need to notify other areas, such as Materials Management, for asset tracking. In turn, the Office of Export Controls and Customs will assess the complete scenario.

If an export license is required, we will file with the appropriate authority to obtain the license. If no license is required, we will inform you. If a license would otherwise be required except that the equipment is to be removed only temporarily, we will provide you a temporary license exception letter. The letter outlines your obligations.

In brief, as the traveler, if a temporary license exception applies, you must:

  • Maintain “effective control” of the item. Regulations define this as: “You maintain effective control over an item when you either retain physical possession of the item, or secure the item in such an environment as a hotel safe, a bonded warehouse, or a locked or guarded exhibition facility. Retention of effective control over an item is a condition of certain temporary exports and reexports.”
  • Not take the item to any of the following countries:
    • Cuba
    • Iran
    • North Korea
    • Syria
  • Protect your software. Directly from the regulations: “Software used as a tool of trade must be protected against unauthorized access.” Examples of security precautions to help prevent unauthorized access include the following:
    • Use of secure connections, such as Virtual Private Network connections, when accessing IT networks for activities that involve the transmission and use of the software authorized under this license exception;
    • Use of password systems on electronic devices that store the software authorized under this license exception;
    • Use of personal firewalls on electronic devices that store the software authorized under this license exception.
  • Return with the item within 12 months.

Question 2: This is a university and I am taking this equipment to support my fundamental research. I am loaning it to another university for only thirteen months. Why do I need to notify anyone?

By leaving the equipment at another university, “effective control” is not maintained. Additionally, the item isn’t planned to be returned within 12 months. In this case, a license might be required, but with a little planning, the Office of Export Controls and Customs can help make the process as easy as possible. Additionally, because the equipment does not qualify for the temporary exception, the equipment’s value might trigger an export reporting requirement.

Question 3: My research equipment has no commercial value. In fact, I am providing the item free of charge, on loan, to another university. The book value is zero. Why would it have to be reported?

Valuation for export purposes follows a defined methodology. Where there is no commercial transaction value, the ECU Office of Export Controls and Customs can help determine the appropriate export value.  Generally, this would be this cost to produce.