MIT intends for all research on campus to qualify as fundamental.
- We don't accept restrictions on publishing scientific and technical information resulting from your research (limited review by the sponsor for information that's proprietary or would compromise patent rights may be acceptable) — these would mean that the research is not fundamental, making it subject to export controls and limiting access. MIT's Open Research and Free Interchange of Information Policy requires campus research to be publishable without prior permission and that foreign researchers not be singled out for restricted access to research.
- Tangible products of fundamental research (models, instruments, devices) are subject to export controls, and may require a license to ship outside the US. Consult the export control officer if you are unsure.
- RAS review of sponsored research proposals and awards helps you ensure that your research is fundamental.
- Avoid using highly controlled export-controlled technology or software that is not classified as EAR99 in your research, as might be provided by a sponsor or vendor. This remains controlled even when used in fundamental research. Sharing it with a non-US person is a deemed export, which may requiring prior US government authorization which would take time and which might not be granted, and this restriction is not consistent with MIT's Open Research Policy.
- Avoid ITAR-controlled items or equipment in your research. Allowing a non-US person access is a transfer of ITAR technical data, requiring prior US government authorization which would take time and which might not be granted. Before bringing ITAR material on campus, approval must be allowed through a TCP.
- Avoid EAR-controlled items with ECCN 9x515 or nx6nn (x = A, B, C, D or E; n = 0-9). These items, which were previously ITAR-controlled, are much more likely to result in deemed export violations than other EAR items. Their use on campus will require a TCP. For example, the ECCN of a certain type of infrared camera is 6A003.b.4a.
- You can use EAR-controlled items, equipment, or materials in your research without restricting access to anyone as long as the use of the material does not impart knowledge of how to replicate the technology.
Open Compliant Research
- RAS review of sponsored research proposals and awards helps you ensure that your research’s compliance with MIT’s Open Research Policy and export control regulations isn’t jeopardized by unexpected export-controlled inputs.
- No side deals — don't make verbal or written promises that undermine fundamental research or open access.
Contact the MIT Export Control Compliance Team at firstname.lastname@example.org, or by phone at 617-253-2762 (Janet Johnston).