Export Controls

Drones

Drones & Unmanned Aircraft Systems
There are many types of Drones or UAV’s (Unmanned aircraft weighing less than 55 lbs). These include consumer versions, military forms, and resourceful products that identify forest fires for firefighters.  These highflyers can be very useful and enjoyable products, but they can also be restricted in many ways.

In keeping within our mission to ensure compliance throughout the university, we advise that the operator be aware of and comply with all federal, state and local laws when handling the drone.  These laws include U.S. Export control regulations and laws.  Restrictions on the export and international sale of unmanned vehicle systems or UAV’s, components, parts, software, and technical data/technology are strict and can be complex. While using, developing or working with any UAV, you need to be aware of existing rules and export control laws.

Product and Technology Classification:
Please ensure you know the proper classification of your drone so as to prevent any “deemed export” release of technology or source code subject to the EAR to a foreign national in the U.S.  

Depending on the drone type and/or its use, it could be restricted by the International Traffic in Arms Regulations (ITAR), which is administered by the Directorate of Defense Trade Controls (DDTC) at the State Department.  These are items specifically designed, modified, or prepared for military end use and are controlled under the ITAR.  If an ITAR-controlled item is incorporated into a new item, that entire new item is subject to the ITAR. A license is required before exporting ITAR items (including services, software and technology) to almost any country and could be an actual export shipment of an item (either purchased from a 3rd party or developed by UC researchers/faculty/staff/students).

Nearly everything else is considered “dual use” and controlled under the Export Administration Regulations (EAR), administered by the Bureau of Industry (BIS) at the Commerce Department. Licenses are required before exporting certain dual use items listed on the Commerce Control List (CCL) to specified destinations. The level of licensing control depends on the item’s Export Control Classification Number (ECCN) and the reason for control listed on the CCL. These items may include technology, technical data, and technical assistance, which are designed for commercial purpose, but may be used for military applications. The Export Controls office can assist you with the following compliance steps:

  • Determining jurisdiction classification of your drone/UAV:
                 1)  USML Cat./ECCN/EAR99
                 2)  Schedule B and HTS number
  • Owner registration (this is mandatory)
  • Classification of items owned or controlled under the correct sections of the ITAR and CCL.  It is impossible to comply with export rules without performing a classification review
  • Implementation of procedures to control unauthorized releases of ITAR and EAR controlled technology, data, items, etc., with a technology control plan (TCP) if necessary
  • Obtaining license from the Directorate of Defense Trade Controls (DDTC) or the Bureau of Industry and Security (BIS), or properly utilize a license exception before exporting controlled items (if deemed necessary by the Export Controls Officer)
  • Review of sanctions, embargoes, and denied parties lists before exporting.  The US maintains comprehensive economic sanctions against other countries.  Any transactions by US persons or the university with these countries or their nationals are generally prohibited or severely limited.  These rules do change frequently so must be checked before export
  • Review of Denied Parties:  The US government maintains lists of individuals and entities, known as "denied parties".  None of the UC faculty, staff, or students may conduct business with denied parties.  The lists can change almost daily.  Contact the Export Control Officer if you have any questions or need assistance.

To learn more, we recommend you visit the FAA website and http://knowbeforeyoufly.org/.

 

Contact Us

Mailing Address:
Export Controls
University Hall, Suite 560D
51 Goodman Drive
PO Box 210567
Cincinnati, OH 45221-0567


Tara Wood
Director, Export Controls
Exportco@uc.edu
513-556-1426



Picture of Tina Bosworth
Tina Bosworth
Sr. Export Control Specialist
Tina.Bosworth@uc.edu
513-558-1128


What to do fact sheet