To prevent strategically sensitive products from ending up in the wrong hands, export control is implemented at Lund University. On this page, you can read more about which products are classified as sensitive and read about the University’s procedures and regulations for export control.
Dual-use items (DUI)
DUIs are products, software or technology with a civil application that can also be used for military purposes. Certain products of particular strategic importance are also classified as DUIs, such as equipment for information security using cryptography. Lund University is mainly concerned with export control of DUIs, which is often a question of ensuring that certain knowledge or information is not disseminated to unauthorised recipients.
Export refers to physical transport and to electronic transfer and verbal transfer of technology. Likewise, publication and cloud services are covered by export control. Exports of DUIs beyond EU borders always require permission. The main rule is that no permit is required within the EU for transfer to another EU member state, but there are exceptions that apply to particularly sensitive products. Even if a permit is not required for transfer within the EU, there is an obligation to inform the recipient if the items being exported are DUIs.
Responsibility and compliance
The responsibility for compliance with regulations on export control lies with the organisation in question. To ensure compliance with regulations, Lund University has its own export control programme for dual-use items (STYR 2020/2073) establishing the University’s export control organisation and clarifying its policy, responsibilities, roles and procedures. The programme also contains a section on the export control process, describing how export control matters are managed.
Anyone exporting should be aware of how the product could be misused, for example in relation to weapons of mass destruction programmes, and take responsibility for ensuring the item does not end up in the wrong hands through theft, hacking, forwarding of information, etc.
What is categorised as a DUI?
Products, software and technology that are classified as DUIs are listed and described in Annex I of the DUI Regulation (Regulation (EU) 2021/821). Annex I is a list of items that require permission for export beyond EU borders, divided into ten categories:
- Nuclear material, facilities and equipment
- Special materials and related equipment
- Materials processing
- Telecommunications and ‟information security”
- Sensors and lasers
- Navigation and avionics
- Aerospace and propulsion
Export control process
If an export permit is required, the organisation is to have the permit in place before initiating the export process. The process of identifying and initiating an export control matter is done within the organisational unit (department or equivalent) where the need to export arises. The researcher/teaching staff member in charge, as the person best informed about the items used, is responsible for communicating the necessary information to the relevant Head of Department so as to enable the latter to have an overview of, and to examine, export control issues connected to their subject field.
To determine whether an item is covered by export control, it must be checked against the regulations using a special checklist. If necessary, a product classification is also to be carried out by the researcher/teaching staff member responsible. Contact the Export Control Officer to get the University’s "Export control: Guide and checklist". If it is necessary to apply for permission to export, this is only done once the matter has been raised via the Head of Department to the Dean responsible for export control, for a decision on further management of the matter.
Classification of DUIs
In order to determine whether a product, software or technology is controlled pursuant to Annex I in the DUI Regulation, the item must be classified. This is done by comparing the product’s properties with the technical descriptions in Annex I. If a description (control text) corresponds to the product or technology in question, the item is a DUI with the equivalent control number. If in doubt about the classification, a product query can be made to the ISP.
To prevent exporters from deliberately evading the intentions of the law, there is a general catch-all clause in the DUI Regulation. This provision entails that if the exporter is aware that the product, software or technology in question could be used for weapons of mass destruction or for military purposes, it can be subject to export control even if the product is not listed in Annex I of the EU’s DUI Regulation.
If the person exporting is aware that DUIs not listed in Annex I of the DUI Regulation, wholly or partially, are intended for weapons of mass destruction or for military purposes, the ISP is to be informed. The ISP subsequently determines whether or not the product is covered by the requirement for a permit in case of export beyond the EU.
As a rule, export is permitted unless there are special reasons to the contrary. However, there are sometimes sanctions in place against certain countries, companies or individuals, which can limit the possibilities for collaboration with them. In Sweden, we adhere to the sanctions decided by the UN, the EU and the OSCE. Examples of sanction measures are weapons embargos, financial sanctions, prohibitions against equipment that can be used for internal repression and prohibition and permit requirements for the export or import of certain goods and certain technologies.
Support and guidance
The Export Control Officer at LU Estates provides university-wide support in the form of coordination, information and advice on export control, as well as develops the export control programme. Some faculties have also appointed local officers for export control. They provide local support to the organisational unit and assist with information and advice. Where necessary, they can also assist in preparing export control matters for processing.
Links to regulations and further information
- Introduction to and regulations on export control, Inspectorate of Strategic Products (ISP) website
- Information on export control concerning category 0, Swedish Radiation Safety Authority website
- Recommendation for research on DUIs, introduction and guidance, Inspectorate of Strategic Products (ISP) website In Swedish
- Current sanctions, Government Offices of Sweden website
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