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Export Controls > Research > Transfer of Tangible Materials


Transfer of Tangible Materials

Providing controlled materials to foreign nationals may require an export license.  The exemption of fundamental university research from export licensing requirements does NOT extend to the export of tangible objects from the U.S. 

There are controls, for example, on the export of tangible materials that could possibly be used in chemical or biological weapons, such as human pathogens, zoonoses, toxins and their clones, animal pathogens, genetically modified microorganisms, plant pathogens, radioactive materials, magnetic metals, propellants and ceramic materials.

If you are planning to transfer tangible materials outside the United States that are controlled by the EAR or ITAR, you should work with the Export Controls Officer to obtain the required export license.

In addition to the above, to transfer materials developed at and/or owned by Cornell University, please contact CTL to arrange for the necessary Material Transfer Agreements; for other materials that are not developed at and/or owned by Cornell University, please contact OSP for the appropriate documentations.

Some questions to ask prior to transferring a tangible material:

  1. Can the material or sample be found in the public domain (i.e. can it be purchased by anyone commercially without restriction)?
  2. Is there a military application for the material (i.e. can the materials be used as weapons)?
  3. Do you have any reason to suspect or believe that the end user may intend or be involved in the design or production of, or re-export or transfer the material or sample to another party for use in the design or production of military or defense related systems?
  4. Does the end user intend to re-export the material or derivative of it?  If so, to whom and to what country?  What is the final intended end use?
  5. Are these materials/samples included in the US Patriot Act or in the List of select agents?
  6. Is the material collected from a patient?  If yes, has an IRB-approved patient consent form been executed?