Can my company enter into collaborative research projects with universities on the Entity List?
Pursuant to §734.8 of the EAR, information resulting from fundamental research is not subject to the EAR. Therefore, given that the collaboration remains limited to fundamental research, it cannot be subject to the Entity List’s licensing requirements and policies. Any research undertaken that involves the export, reexport, or transfer of an item subject to the EAR and that does not conform to the requirements of § 734.8 of the EAR may, depending on the licensing requirements and policies specified in the Entity List entry, require a license from BIS.
