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Assessing your online course content

In order to determine whether the content of the course you are planning is subject to export control restrictions, you need to use the  UK strategic export control list and the goods checker tool, both provided by the UK Government.

The strategic export control list provides descriptions of controlled goods. It is almost 300 pages long, so to navigate it, use the goods checker tool to search for keywords (an exhaustive range) within it and identify the sections of the list that are relevant to you. Even though we recognise most exports from the University will be related to technology, in order to identify the technology code, you must first identify the physical goods code associated with it. You need to search for the physical goods that 1) you describe or include in your course content (samples, materials, equipment) as well as 2) those physical goods that the information from the course will be applicable to. For instance, if your course is about materials (name of the material) for the development of aeroengines (the engine/aircraft).

If you are unable at first to find your goods, software or technology (information or data) in the lists using the goods checker, it does not mean that they are not controlled. You might need to run an exhaustive search of keywords as the goods checker tool is based on very specific terminology used within the strategic export control list. The ECC team has provided this short video to highlight the importance of using the right key words in this process (the video link requires CAS authentication).

Be aware that end-user controls are “catch all” controls and apply to anything (even technology not listed in the UK consolidated list) if there are concerns of WMD or military end-use associated with the end-user. If you are preparing the material for a specific student exchange agreement between the University and another institution or as part of a CPD program under an agreement between the University of Manchester and a company, and your assessment indicates that the content is not controlled (as listed in the UK consolidated list), you must still fill in form ECCF5c to request due diligence checks on the institution/company by the Export Control Compliance (ECC) team.

To determine if there are any technology codes that could apply, begin by assessing your teaching content following the steps below:

1. Visit the goods checker tool, scroll down and select the first Goods checker link

2. In the search box enter a key word such as:

    • a physical good that you use or refer to in your teaching (ie samples, materials, equipment) and
    • a physical good in which your teaching content will apply to (ie equipment, materials, processes) and
    • a related teaching output (ie algorithms to develop aircraft, ‘aircraft’ being the word inserted as a key word here)
  • Depending on your search query, the number of results you receive will vary, you may need to scroll down to identify the terms relevant to your work
  • Once you have identified the code (eg 9A012) for a physical item (which you might not export), you need to identify the technology code associated with that physical item code. There are ten categories within Annex I, numbered from 0 to 9. Within each of these categories, there are 5 subcategories lettered A to E, where A to D refers to physical items and E refers to technology. Unfortunately, the current search results of this step do not provide all applicable E codes, thus, to obtain them, see step 4
  • Remember, the terms you use in your searches are important: use as many alternatives for your item as possible. For example, if you’re checking ‘drones’, use alternative terms such as ‘UAV’. You must do numerous searches to exhaust all possibilities relevant to your physical goods that are related to your research project

3. Once you’ve identified a relevant entry, click on the symbol/icon next to it (as you hover over the symbol/icon it will pop up the 'View Goods Checker Entry' message) to expand the entry and view further information (which may include further technical ‘thresholds’ details such as physical parameters or capabilities) of the control restrictions.

  • If you hit these thresholds, the good is controlled and you may need a licence to export that physical good but the technology associated with it may or may not be controlled. Go to step 4 to identify the technology code associated with this controlled physical good
  • If you do not hit the thresholds, the physical item is not controlled, but the technology associated with it may be still controlled in some circumstances due to the General Technology Note. Find the associated technology code as described in step 4
  • Alternatively, you may wish to consider adjusting your proposed work to keep it under the controlled thresholds, this way no export licences may be required

4. To identify a technology code related to a physical code in the EU dual list, visit the goods checker tool, scroll down and select the first ‘Goods checker’ link:

  • Select 'goods checker browse' on the left
  • Expand the 'Annex I list of dual-use items' and expand the category for the code you have found applicable to the physical item related to your research
  • Expand the 'E technology' entry and select the E code that corresponds to the physical goods code you have previously identified, this being “developing”, “producing” or “using” the physical item. Note: doing research usually falls under “developing”. If your activity falls under the definition of the relevant E code, the technology is controlled, and you might need to apply for an export licence

Teaching content evolve with time and can move towards different teaching outcomes than originally planned. When changes occur, it is your responsibility to re-assess any courses you're involved in and put an export licence in place if necessary. 

Technology

Technology includes any specific information1 necessary for the development2, production3 or use4 of goods which are subject to controls.

1 Information could be in the form of but not limited to blueprints, plans, diagrams, models, formulae, tables, source code*, engineering designs and specifications, research data, manuals, instructions, either written or recorded on other media or devices such as disks, tapes or read-only memories. It also refers to skills, training, working knowledge or consulting services.

*source code (or source language) is a convenient expression of one or more processes which may be turned by a programming system into equipment executable form.

2 Development, means all stages prior to "production" (e.g. design, design research, design analyses, design concepts, assembly and testing of prototypes, pilot production schemes, design data, process of transforming design data into goods, configuration design, integration design, layouts).

3 Production means all production stages (e.g. product engineering, manufacture, integration, assembly (mounting), inspection, testing, quality assurance).

4 Use means operation, installation (e.g. on-site installation), maintenance, checking, repair, overhaul and refurbishing.

General technology Note (GTN)

The intent of the GTN is to control only that portion of “technology” that is specific to controlled items. The result is that any “technology” that is shared between controlled and non-controlled dual-use items is not controlled. For example, if the technology used to produce an analogue to digital converter with a -55 to + 125 degree operating temperature range, is the same as that used to produce one with a reduced operating temperature range, then it is not controlled.  If, however, the “technology” needed to produce the extended temperature range device is different to that used to produce the reduced temperature range device, then the “technology” used to produce the former would be controlled.

Nuclear technology Note (NTN)

This is similar to the EU Dual-Use Regulation GTN but brings into control all “technology” directly associated with nuclear goods controlled in Category 0 of Annex 1 to the Regulation.