Export control

International relations and partnerships in research, teaching and knowledge transfer are an integral part of ETH Zurich’s work environment.

Export control
The Goods Control Act and the Embargo Act form the basis of export control.

They regulate the cross-border exchange of goods for civilian and military use (dual-use goods) and war materials. These include products, technologies (information and knowledge) and software (collectively referred to as goods).

Listed goods are subject to approval by the State Secretariat for Economic Affairs SECO when exported from Switzerland. Where the exchange of controlled goods involves US origin, US licences may also be required.

The embargo laws apply as soon as a recipient is in a state subject to sanctions.

For years, sanctions have focused primarily on North Korea, Iran, Syria and Sudan as well as Russia and Belarus. Other sanctioned countries appear on embargo lists in Switzerland, the EU and the USA.

The exporter, i.e. the person who has knowledge or goods dispatched from Switzerland, is obliged to check both the end user and the final use.

The classification of the goods determines whether export controls apply. 

Classification of goods
The export control number and the origin of the goods form the basis for the classification of goods. The export control number is determined from goods control lists. The origin of goods indicates the country in which the goods were obtained, produced, or researched. 

Only by determining the export control number and the origin of the goods can an assessment be made as to whether, in addition to Swiss export control laws, US export control laws also need to be considered and whether an official export permit is required.

ETH Zurich areas affected by the cross-border movement of goods (not exhaustive):

• Purchase of export-controlled goods and software intended as temporary exports from Switzerland.
• The sale, rental, brokering or donation of export-controlled products leaving Switzerland.
• Research cooperations and contracts for grants where the contract contains export control clauses.
• The hiring process for employees and the admission process for Master’s students; invitations of visiting professors and academic guests from embargoed countries who provide access to export-controlled areas and to unreleased, controlled technology.
• Travel abroad with mobile devices on which export-controlled software and technologies are stored.

The five key issues in export control:

1. WHERE do the goods come from? Country of origin of the goods
2. WHAT is to be exported? Goods, technology or software
3. WHERE are the goods to be exported to? Final destination country of the exported goods
4. WHO is to receive the goods? Final consumer and whether an embargoed country is involved
5. WHAT will the goods be used for? End-use of the goods in the country of destination

Only if the export control examination has taken place and any necessary approval has been granted by the authorities may an exchange of knowledge, a cross-border supply of goods and software, or the provision of a service take place.

Exemptions
Basic scientific research, information on patent applications and research results already published and made freely available to the public are not subject to an export control examination.

Help with implementing export controls
Detailed information can be found on the ETH Export Control website.

Responsibility for implementing Swiss, EU and US export control regulations rests with any person who exports or exchanges goods from Switzerland across borders. Overall responsibility, however, lies with the budget officers and managers in the units in question (e.g. professors, heads of departments, heads of staff units).