Resources for Departments - EC

Laptop and GPS Checklist

Faculty and employees effectively export their laptops or GPS when they:

  • Take equipment abroad to aid them with their research and other international activities;
  • Allow a person in a foreign country to use their laptops or GPS; or
  • Allow a foreign national access to their laptops or GPS in the United States (a "deemed export").

Laptops and GPS, and their underlying software, are covered by the Export Administration Regulations ("EAR") and, in some cases, the International Traffic in Arms Regulations ("ITAR"). Export regulations vary based on which country you are traveling to and for what purpose you intend to use your laptop or GPS. In addition, a licensing exception may apply to the export of the laptop or GPS in question, and if so, you potentially could take that equipment abroad without violating the EAR or ITAR.

If the checklist below suggests that transferring your laptop or GPS might trigger U.S. export control regulations, you must contact the Office of Export Controls for an analysis of whether an export license is required. This analysis must occur before the laptop or GPS is exported.

If you are not traveling to Cuba, Iran, North Korea, Syria or North Sudan AND you plan to bring a standard consumer laptop with standard mass-market software that the manufacturer confirms may be exported, you do not need to complete this checklist. You should satisfy yourself that these conditions are met by checking the status of your equipment and software on the manufacturer's website. Export control websites for common manufacturers include:

If you are unsure whether your laptop is a standard consumer laptop or whether your laptop contains software that is not standard, mass-market software, you should complete the checklist below.

Laptop, GPS, Electronic Devices Checklist

A license exception to U.S. export control regulations will apply to the USF owned laptop, PDA, Digital Storage Device and/or GPS equipment and its operating software if the software or technology comes within the TEMPORARY EXPORT EXCEPTION because:

  1. The software does not contain source code for 64-bit or higher encryption software or mass market encryption products, AND
  2. The device, equipment, software and/or technology is not on the United States Munitions List ("USML") under the International Traffic in Arms Regulations ("ITAR") 
  3. (See the e-CFR site for a list of items on the USML — please carefully review Category XV if you are exporting GPS equipment.), AND
  4. The device, equipment, software and/or technology will not be put to a military use OR used in outer space, AND
  5. There is no reason to believe that your research could be used in the development of weapons of mass destruction, AND
  6. Transfer of your laptop, PDA, Digital Storage Device, or GPS and its operating software to a foreign country falls under the TEMPORARY EXPORT EXCEPTION - TOOLS OF THE TRADE because:
    • The item(s) will be returned to the U.S. within one year of the export date, AND
    • The item(s) is a "tool of the trade" because it is a usual and reasonable type of tool of trade for use in lawful research, AND
    • You will retain effective control over the equipment while abroad by retaining physical possession of the item or securing the item in a secure environment such as a hotel safe, AND
    • You are not exporting the item to Cuba, Iran, North Korea, Syria or North Sudan, AND
    • You are not and will not be using this item in relation to any type of nuclear research.

All items must be checked in order for the Temporary Export Exception (TMP) TOOLS OF THE TRADE to apply.