Export Compliance and Travel with Portable Electronic Devices

When leaving the country, everything taken with you is considered an export. The physical items, the underlying technology, and any data which may reside on them are all subject to export control regulations. It is the traveler’s responsibility to ensure that their equipment, electronic devices, files, and presentations do not contain any export-controlled technical data or technology, and to coordinate with the export compliance team in the Office of Research Compliance (ORC) to determine if any applicable licensing or filing requirements apply to their export.

In most cases (as described below), traveling outside the United Stated (U.S.) with UMaine-owned laptops, tablets, cell phones, and other Portable Electronic Devices1 with standard software will not require an export license, provided the equipment is always under the traveler’s control and returns to the U.S. within one year. 

All personnel traveling internationally with Portable Electronic Devices should review the University of Maine Advanced Research Computing, Security, and Information Management (ARCSIM) travel guidance for data security which includes tips for travelers for before, during, and after travel, and addresses steps travelers should take when traveling to certain foreign countries where it is illegal to use encryption on devices.

Temporary Export Certification Requirements

Please use the guidance below to determine if review by ORC Export Compliance is needed for your international travel with Portable Electronic Devices. Note: If you are exporting more than just Portable Electronic Devices, please see Physical Exports.

If the following statements are all true for the export of your Portable Electronic Device(s), please complete the Temporary Export Certification Form and keep a signed copy of the Certification with you when traveling abroad:

  1. The Portable Electronic Device will not be taken to an OFAC Sanctioned Country (external link), including but not limited to Belarus, Cuba, Iran, North Korea, Russia, or Syria, or to a country subject to Military End Use Controls, including China, Burma, Cambodia, Nicaragua, or Venezuela.
  2. The Portable Electronic Device does not include any software that is not part of the standard set of software pre-installed on the device or commonly available for download without restriction (such as standard office software or educational versions of commercially available software). Note: if the device incorporates specialized scientific software (excluding typical operational software like Microsoft Office, Adobe, etc.) and/or software programs containing or constituting specialized cryptographic functionality (excluding routine commercial laptop cryptographic protection), please contact um.export@maine.edu for guidance.
  3. The Portable Electronic Device contains only information that is publicly available, the results of fundamental research, or educational information, and does not contain any technical data, research data/results, or accessible source code that is considered proprietary or otherwise not intended for publication.
  4. The Portable Electronic Device is not a prototype.
  5. The Portable Electronic Device will not remain outside the U.S. for over 12 months.
  6. You have reviewed University of Maine Advanced Research Computing, Security, and Information Management (ARCSIM) travel guidance for data security and you will protect information on the Portable Electronic Device(s) from unauthorized access by employing appropriate protections such as using secure connections [e.g.  Virtual Private Network (VPN)], strong passwords, firewalls, etc.
  7. You acknowledge that it is best practice to maintain effective control of the Portable Electronic Device while abroad. (You maintain effective control over an item when you either retain physical possession of the item, or secure it in a location such as a hotel safe or a secure area.)

If all of the statements above are true, proceed to complete the Temporary Export Certification Form.

If one or more of the statements above is false, please contact ORC Export Compliance for assistance in determining applicable licensing requirements and/or the availability of a license exception.

  1. Note: All italicized links direct to the ECR Glossary. ↩︎