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Resources for Researcher » Hand-Carry Tools

Hand-Carry Tools

Traveling with University Equipment and Software

Under the “Tool of Trade” license exception travelers can hand-carry usual and reasonable kinds and quantities of university owned equipment and software for use by employees in a lawful enterprise.

The “Tool of Trade” license exception has several requirements.

"Tool of Trade" Requirements

• The destination cannot be to a sanctioned country,
• Use of the “Tool of Trade” exception must be documented on a certificate,
• Equipment and data cannot be on the International Traffic in-Arms (ITAR) U.S. Munitions List (USML) (e.g. DoD Sponsored project articles or data not in the public domain),
• Equipment and data must be in the  ”effective control” of the traveler for the duration of the trip and cannot be released,
• Equipment and data cannot be out of the U.S. for longer than 12 months.

”Tool of Trade” Certificate

Traveling with university equipment to an international destination may qua0ify for a “Tool of Trade” exception.

• To determine if travel with equipment will qualify for the “Tool of Trade” exception, complete the following checklist, 
• If the checklist indicates the exception applies, complete the “Tool of Trade” Certificate, retain the signed original as part of your travel documentation,
• Submit a copy to the Office of Export Compliance by email or campus mail.

The exception certificate demonstrates the traveler understands the export requirements associated with equipment or data being exported and that exports to sanctioned/embargoed countries are prohibited.   For additional information contact the Export Control Officer.

What Equipment Qualifies for an Exception as a "Tool of Trade"?

Equipment
Qualifies	Does Not Qualify
Standard laptop with pre-loaded commercial software, Some laboratory equipment depending upon the travel destination,  Most commercially available items.	Agents, toxins, microorganisms, pathogens, chemicals or nuclear technologies, High end GPS units, Defense articles listed on the ITAR U.S. Munitions List (USML).

Software
Qualifies	Does Not Qualify
Standard off-the shelf mass-market software (i.e. MS Office products) if carried to 35 favorable countries, Non-encryption beta test software to be marketed after testing.	Non-standard cryptography technology and software, (non-mass market software), “open cryptographic interface” technology or “cryptanalytic (code-breaking) technology for export to any country other than the 35 favorable countries.

Data

Removed the following types of data from a laptop before departure as they do not qualify for the “Tool of Trade” exception: Proprietary technical data not intended for public distribution, such as sponsored research with access, publication, or participation restrictions, Technical data relating to the development, production, or use of an commodity listed on the EAR Commerce Control List (CCL), Data relating to any military sponsored project or defense articles on the ITAR U.S. Munitions List (USML).

“Reasonable suspicion of any crime or wrongdoing is not needed for customs officials to search a laptop or other personal electronic storage devices.” Additional information is available in the ”Policy Regarding Border Search of Information” by U.S. Customs and Border Protection.

Traveling with Non-University Equipment

License Exception BAG (Baggage) allows US citizens to carry family-owned retail-level items including laptops, personal digital assistants (PDAs), and cell phones as personal baggage. The items and software must be for their personal use.

Disclaimer: The contents of the Office of Export Compliance website have been prepared for the UCF research community for informational purposes and are not intended to replace any regulatory document of interpretation or to relieve importers or exporters of their statutory responsibility to comply with current laws, regulations, policies and procedures of the U.S. Government. Website content may not apply to other specific situations that occur outside of the UCF research community or may be incomplete and do not constitute legal advice or the provision of legal services. Those outside of the UCF research community should not act upon any material within this website without seeking professional counsel.