Classification and export screening procedures

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Classification and export screening procedures

Item classification at Aalto University in the context of export control and sanctions seeks to understand whether an item (tangible or intangible) falls within the scope of any relevant control list. The classification and export screening procedures serve as a framework to identify and categorize research and innovations, while ensuring compliance with import and export control regulations. The procedures are designed to protect intellectual property, maintain national security, and abide by international trade laws. By following this approach, we can confidently navigate the complex landscape of global research standards and facilitate the seamless sharing of knowledge and technology across borders.

Item classification seeks to achieve understanding on whether an item within the scope af any relevant control list

Item classification seeks to understand whether an item (tangible or intangible) used or produced in the framework of research at Aalto falls within the scope of any relevant control list, and also whether a research project will be confronted with any items mentioned in any of the control lists referred to below.

The control lists most applicable 91�� are the EU list of dual-use items and Finland's national control list, the latest version of which can be read here Control lists | Aalto University

However, also the following control lists need to be kept in mind, although usually:

the EU common list of military items (Control lists | Aalto University) is not relevant – and it does not have to be examined – for a research activity if there is no intention on the part of Aalto’s personnel involved in such activity to specially design or modify something for military use; and
the control lists of are not relevant – and they do not have to be examined – if no collaborators directly or indirectly involved in the research activity are affiliated with institutions or entities in any sanctioned or embargoed countries. For information on EU sanction programs against a particular country please see (select a country and review the information given related to the selected country).

In some cases, also the US control lists need to be considered.

Classification is done by comparing the characteristics of an item against the descriptions or definitions given in the relevant control list(s) and requires knowledge on both the subject and scope of research, including what input is used and what the expected and actual output is, and the contents of the relevant control list(s). The comparison is best carried out as a joint effort of the PI (with support from his/her team members) and the technical export control expert of the relevant School or Department.

In the event that an item used in Aalto research activity is produced outside the University, for example a payload produced by a collaborator comprising scientific measurement equipment for a satellite produced in Aalto, the recommendation is to require the collaborator (in this example the party that produced the payload) to carry out the classification of the item it produced.

The outcome of the item classification determines whether a license is required for export or provision of technical assistance. If a license is required, Aalto University and its personnel cannot undertake any activity in the absence of such license or contrary to the provisions of license received.