Determine whether you're working with controlled items

In order to determine whether your research is subject to export control restrictions, you need to use the UK strategic export control list and the goods checker tool, both provided by the UK Government.

The strategic export control list provides descriptions of controlled goods. It is 300+ pages long, so to navigate it, use the goods checker tool to search for keywords (an exhaustive range) within it and identify the sections of the list that are relevant to you. Even though we recognise most exports from the University will be related to technology, in order to identify the technology code, you will first be required to identify the physical goods code associated with it. You need to search for the physical goods that 1) you use in your research (samples, materials, equipment) as well as 2) those physical goods that you research will be applicable to. For instance, you are working with materials (name of the material) for the development of aeroengines (the engine/aircraft).

If you are unable at first to find your goods, software or technology (information or data) in the lists using the goods checker, it does not mean that they are not controlled. You might need to run an exhaustive search of keywords as the goods checker tool is based on very specific terminology used within the strategic export control list. The Regulatory Compliance Team (RCT) team has provided this short video to highlight the importance of using the right key words in this process (the video link requires CAS authentication).

To determine if there are any technology codes (including those relating to emerging technologies such as quantum, cryogenic and semiconductor technologies) that could apply, begin by assessing your research following the steps below:

1. Visit the goods checker tool, scroll down and select the first Goods checker link

2. In the search box enter a key word such as:

• a physical good that you use in your research (i.e., samples, materials, equipment) and
• a physical good in which your research will apply (i.e., equipment, materials, processes (including manufacturing) and
• a related research output (i.e., algorithms or software to develop aircraft, ‘aircraft’ being the word inserted as a key word here)

• Depending on your search query, the number of results you receive will vary, you may need to scroll down to identify the terms relevant to your work
• Once you have identified the code (e.g., 9A012 or ML17, PL9013) for a physical item (which you might not export), you need to identify the technology code associated with that physical item code. There are ten categories within Annex I, numbered from 0 to 9. Within each of these categories, there are 5 subcategories lettered A to E, where A to D refers to physical items and E refers to technology. Unfortunately, the current search results of this step does not provide all applicable E or PL codes, thus to obtain them, see step 4.
• Remember, the terms you use in your searches are important: use as many alternatives for your item as possible. For example, if you’re checking ‘drones’, use alternative terms such as ‘UAV’. You must do numerous searches to exhaust all possibilities relevant to your physical goods that are related to your research project.

3. Once you’ve identified a relevant entry, click on the symbol/icon next to it (as you hover over the symbol/icon it will pop up the 'View Goods Checker Entry' message) to expand the entry and view further information (which may include further technical ‘thresholds’ details such as physical parameters or capabilities) of the control restrictions.

If you hit these thresholds, the good is controlled and you may need a licence to export that physical good but the technology associated with it may or may not be controlled. Go to step 4 to identify the technology code associated with this controlled physical good.

• If you do not hit the thresholds, the physical item is not controlled, but the technology associated with it may be still controlled in some circumstances due to the General Technology Note. Find the associated technology code as described in step 4
• Alternatively, you may wish to consider adjusting your proposed work to keep it under the controlled thresholds, this way no export licences may be required

4. To identify a technology code related to a physical code in the EU dual list, visit the goods checker tool, scroll down and select the first ‘Goods checker’ link:

• Select 'goods checker browse' on the left
• Expand the 'Annex I list of dual-use items' and expand the category for the code you have found applicable to the physical item related to your research
• Expand the 'E technology' entry and select the E code that corresponds to the physical goods code you have previously identified, this being “developing”, “producing” or “using” the physical item. Note: doing research usually falls under “developing”. If your activity falls under the definition of the relevant E code, the technology is controlled, and you might need to apply for an export licence.
• Technology related a military ML code comes under control rating ML22. Technology related to dual use PL codes is not yet listed in the goods checker, however you can read about them in the regulations.

Research projects evolve with time and can move towards different outcomes than originally planned. When changes occur, it is your responsibility to re-assess any project you're involved in and put an export licence in place if necessary. 

Once you have identified the relevant code applicable to your project, you should submit the export control compliance request form and provide the regulatory compliance team with the applicable code. If you are unsure on how to assess your project, also contact the RCT to guide you on how to self-assess your project.