UCD Statement on Export Controls

The mission of UCD is to create knowledge, to empower learning and to engage with partners to drive impact from education and research. UCD's world extends beyond its campus, city and borders and UCD faculty engage in international research collaborations, sharing and contributing to a global bank of knowledge. 

This statement and our actions are a response to the internal compliance guidance set out in EC Recommendation 2021/1700 in order to comply with Regulation (EU) 2021/821. The University understands the importance of Export Controls and it is strongly committed to ensuring that the UCD Community comply with applicable Export Control laws and regulations. The purpose of Export Controls is to restrict the transfer of certain goods, technologies, and services to non-EU countries in order to prevent their unauthorised use or proliferation. It is important to note that Export Control regulations not only apply to the transfer of physical items but also to the physical, electronic or verbal transfer of intangible information. Intangible exports can include software, data, designs, knowledge or knowhow.

In order to support our research community in complying with this legislation, we have a Policy on Export Controls which has been endorsed by the University Management Team, a dedicated website is in place, Export Control training is freely accessible on Brightspace, and a number of Units including our Research, Legal, Compliance and Risk colleagues continue to actively raise awareness of Export Controls throughout the University. We have also appointed a Research Policy Officer (RPO) to oversee the governance and compliance with the Export Control Policy. You can submit a (opens in a new window)query online or email the RPO at (opens in a new window)exportcontrol@ucd.ie.

Date: February 2025

UCD Procedures for Export Control compliance:

1. Researchers are required to undertake the training on Export Controls provided by UCD on (opens in a new window)Brightspace (Export Controls Training module) to ensure that they are fully informed on what constitutes a product or activity that is subject to Export Controls.

2. Researchers must assess their research activity at the earliest possible stage, to ascertain if it falls under the Export Control legislation. A decision support tool is available to help you do this. A wide range of research activities could trigger dual-use Export Controls.

3. The EU has produced military and dual-use lists of restricted products and activities, and researchers should check these lists to assess whether their research falls under this legislation. The (opens in a new window)Research Policy Officer can assist with this assessment. 

4. The Research Policy Officer will review and assess the information provided by the researcher in the decision support tool. This helps them to support the researcher's assessment and is also necessary for record keeping purposes.

5. The Research Policy Officer, in collaboration with the researcher, makes a decision on whether an Export Control licence application is required or not. Note that the process of obtaining an export licence may take a number of weeks, and any assessment of the need for a licence and an application for same needs to be done as early as possible.  

6. The actions below follow this decision:

   • If no Export Control licence is required, the Research Policy Officer records their assessment of the information provided and no further action is required.

   • If the Research Policy Officer has any queries, they will liaise with colleagues in relevant support units who will provide additional guidance.

   • If an Export Control licence is required, the Research Policy Officer, in liaison with SIRC, will assist the researcher in accessing the online portal and completing the Export Control licence application to the Department of Enterprise, Trade and Employment (DETE).

7. Once a licence has been issued by DETE, the Research Project Officer will discuss any terms of the licence with the researcher as well as their record keeping and audit responsibilities.

8. An export cannot take place until the licence has been issued by DETE and the export must comply with all terms of the licence.

9. When exporting physical items using a freight forwarding service or similar, it is important to ensure that they satisfy professional standards. It is also essential to provide clear written instructions to the freight forwarding agent which will include the full licence details, an explanation of the implications of licence for the export (e.g., for routing) and their responsibility for documentation (e.g., returning completed customs declaration for UCD records).