Export Controls

At Queen Mary University of London, research is built on international collaboration and the open exchange of ideas. In some circumstances, however, UK law places controls on the transfer of certain goods, software, technology and technical knowledge. 

Export controls are designed to protect the UK's national security, international obligations and foreign policy interests. They do not prevent legitimate research from taking place but help ensure that research with potential military, dual-use or strategic applications is managed responsibly. 

As a researcher, you play an important role in identifying potential export control risks before research begins. By considering export controls early, you can avoid delays, protect your research and ensure your project complies with UK legislation. 

The Research Security Team is here to support you throughout this process. 

What are Export Controls? 

Export controls regulate the transfer of specific goods, software, technology and technical information outside the UK. They also apply to certain activities involving overseas organisations and individuals, even where no physical item leaves the country. In many cases, research activities will not require an export licence. However, some projects require additional assessment before work begins. 

Export controls can apply to: 

• physical equipment 
• laboratory materials 
• scientific instruments 
• specialist software 
• technical data 
• research methodologies 
• engineering designs 
• source code 
• technical advice or training 

An export may occur through: 

• shipping equipment overseas 
• emailing controlled technical information 
• providing access to cloud storage 
• sharing research data 
• presenting detailed technical information at conferences 
• collaborating remotely with overseas partners 
• allowing overseas visitors access to controlled technology. 

What Counts as an Export?

Export is often associated with shipping equipment and products overseas. However, in research context, an export can also occur when controlled technology, software, or technical information is transferred to an individual or organisation outside the UK. This may include:

• emailing technical information to an overseas collaborator
• uploading controlled information to shared cloud storage
• allowing controlled technology to be accessed remotely from outside the UK
• presenting detailed technical information at conferences, meetings or workshops
• providing overseas visitors with access to controlled technology, software or technical data

As a result, export controls may apply even where no physical item leaves the UK.

Why Export Controls Matter?

Universities have a legal responsibility to comply with UK export control legislation. 

Failure to comply may result in: 

• delays to research 
• inability to transfer research outputs 
• criminal or civil penalties 
• reputational damage to researchers and the University 
• restrictions on future funding or collaborations. 

Considering export controls at the earliest stage of research planning helps avoid these risks. 

Export controls help ensure that sensitive technologies are not used in ways that could: 

• threaten national security 
• contribute to weapons programmes 
• support military capability inappropriately 
• breach UK sanctions 
• undermine international security commitments. 

Your responsibilities

Every researcher is responsible for considering whether export controls may apply to their work.

This includes:

• considering export control implications when developing a research proposal
• identifying whether technology, software or equipment could be controlled
• considering overseas collaborators and end users
• discussing potential concerns with the Research Security Team before research starts
• following advice provided during the due diligence process
• obtaining any necessary approvals before controlled information is shared.

If you are unsure whether export controls apply, contact the Research Security Team for advice before proceeding.

When Export Controls may apply?

Export controls should be considered whenever research involves: 

1. International collaborations 

Working with overseas universities, research institutes, governments or commercial organisations. 

2. Controlled technology 

Developing or using technology listed within UK Strategic Export Control Lists. 

3. Dual-use research 

Research that has legitimate civilian applications but could also have military or security uses. 

4. Overseas travel 

Taking research equipment, software or technical information outside the UK. 

5. Knowledge transfer 

Providing technical advice, demonstrations or training to overseas individuals or organisations. 

6. International visitors 

Providing access to controlled facilities, laboratories or technical information. 

Research involving Dual-Use Technology 

Many research projects involve technologies with entirely legitimate civilian applications. Some of these technologies are classified as dual-use, meaning they could potentially be used for both civilian and military purposes. Being classified as dual-use does not mean research cannot proceed. Instead, it means additional assessment may be required to determine whether legal controls apply. Early discussion with the Research Security Team helps ensure appropriate advice is provided without creating unnecessary barriers to research.

Applying for Export Control Licenses

The Research Security team  will provide  advice, and guide you through the University's due diligence and export control license application process.

Researchers should first establish whether the proposed export involves controlled goods, software, technology or technical information, and identify the relevant UK control-list classification and destination. An export license may also be required because of end-use or sanctions controls. Applications are made to the UK Export Control Joint Unit (ECJU) by the Research Security team

For a specific export to a named overseas recipient, a Standard Individual Export License (SIEL) is usually appropriate. The application requires details of the item/technology, classification, quantity, destination, consignee, end-user and intended end-use, together with supporting documents such as an end-user undertaking. Researchers must not export until the required license has been granted.

An Open Individual Export License (OIEL) may be suitable for recurring exports and can cover multiple shipments or destinations, subject to its conditions. OIEL applications can take several months.

An Open General Export License (OGEL) is a pre-issued license covering specified controlled items and destinations. It can avoid an individual license application for each shipment, provided the university registers for the relevant OGEL and complies fully with its conditions and record-keeping requirements.

Researchers should not export until the required license or approval has been obtained. ECJU assesses applications case-by-case and may consult other government departments.  For SIELs, ECJU aims to decide 70% within 20 working days and 99% within 60 working days. However, actual processing can take longer, particularly for sensitive destinations, complex technology or cases requiring further information or interdepartmental consultation.

Additional Information

External Sources of information: UK Strategic Export Control

Note: Research Security policies and guidance documents are available on the Policies, Guidance and Training page