On this webpage, we are making available relevant resources to help navigate the increasingly complex environment for international research. This website will be expanded and updated with information. Researchers are encouraged to check the website on a regular basis. All researchers are expected to be familiar with and comply with the information on this website. 

Collaborating with Foreign Entities

  • Providing professional services or financial assistance to certain countries, persons, or entities may fall under export control. 
  • Fundamental research and results of research that will be in the public domain are generally excluded from export controls. “Fundamental research” is defined as “research in science, engineering, or mathematics, the results of which ordinarily are published and shared broadly within the research community, and for which the researchers have not accepted restrictions for proprietary or national security reasons.”1
  • Prior to executing an agreement with or including a foreign collaborator, to determine whether or not there is any export control related information or material being exchanged as part of the agreement, the Division of Research will screen all of the individuals and entities related to the transaction for a possible match in Visual Compliance. The Visual Compliance screening searches the names of individuals and company against government restricted party lists and provides a report. 
  • Individual researchers may not make any arrangements or commitments with a prospective partner or funding source without going through the appropriate university offices and administrative procedures. Contact your Fiscal Manager in the Office of Sponsored Programs.

Federal Agency Requirements on Grants

  • The National Institutes of Health (NIH) requires the disclosure of all sources of research support, foreign components, and financial conflicts of interest for senior/key personnel on research applications and awards. This includes support coming from foreign governments or other foreign entities (see NIH Grants Policy Statement Section 2.5.1). 
  • NIH requires in grant applications to indicate whether or not the project includes a “foreign component,” and if so, to provide a justification. A foreign component is defined in the NIH Grants Policy Statement, Section 1.2, as “[t]he performance of any significant element or segment of the project outside the United States either by the recipient or by a researcher employed by or affiliated with a foreign organization, whether or not grant funds are expended. Examples include collaboration with investigators at a foreign site; use of facilities or instrumentation at a foreign site; or financial support or resources from a foreign entity. Foreign travel for consultation is not considered a foreign component.” 
  • The National Science Foundation (NSF) requires senior personnel to disclose Current & Pending Support as part of the proposal (see NSF Proposal & Award Policies & Procedures Guide Chapter II). Current and pending support includes all resources made available to an individual in support of and/or related to all of his/her research efforts, regardless of whether or not they have monetary value (for detailed requirements, see the PAPPG Chapter II). 
  • In December 2018, the U.S. Department of Energy (DOE) issued a memorandum informing DOE grant, fellowship, and center recipients that they are prohibited from using U.S. tax dollars to conduct international research collaborations or support sensitive country foreign nationals in areas that were not specified in the memo but could include, according to Science, artificial intelligence, supercomputing, quantum information, nanoscience, or advanced manufacturing. 
  • In June 2019, the DOE issued the DOE Order 486.1 that prohibits DOE employees, contractors, and certain subcontractors from currently or in the future participating in foreign talent recruitment programs of countries determined sensitive by DOE, such as China’s Thousand Talents programs.  
  • In March 2019, the U.S. Department of Defense (DOD) issued a memorandum stating that proposers for all non-procurement transactions must submit detailed information on other current and pending support for all “key personnel.” 
  • Since 2011, NASA is prohibited "from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, whether funded or performed under a no exchange of funds arrangement. Proposals involving bilateral participation, collaboration, or coordination in any way with China or any Chinese-owned company, whether funded or performed under a no exchange of funds arrangement, may be ineligible for award." 

Foreign Nationals Visiting MSU

  • Foreign nationals are not allowed access to controlled technologies. Sharing information about controlled technologies or sharing controlled technologies with foreign nationals falls under U.S. export control regulations. Export control not only includes shipping or carrying items to foreign countries, but also sharing controlled technology or information with foreign nationals within the U.S., which is known as a "deemed export." Note that U.S. permanent residents are not considered foreign nationals. 
  • If you host visitors in a lab, make sure you follow the Non-Employee Appointments Policy, complete the appropriate forms that can be found on MSU's Non-Employee Appointments Policy webpage, and provide appropriate lab safety training to ensure their and others’ safety. Be aware that different countries may have different safety standards, and visitors may not be familiar with the standards at MSU. 
  • If visitors plan to participate in research with human or animal subjects, ensure they are added to applicable regulatory protocols (IRB, IACUC, etc.) and have taken the associated ethical training. Be aware that different countries may have different ethical standards for research. 
  • Hosting visitors in your research group can pose intellectual property issues. Discuss project ownership and determine the need to execute a confidentiality agreement prior to collaborating. Ensure the appropriate Agreement is in place prior to engagement with the collaborator. Becautious of activities like adding unrelated visitors with little advance notice. 
  • Material Transfer Agreements (MTAs) are required for the exchange of research materials into or out of the university. 

International Travel

  • The Office of International Programs maintains detailed information on travel. Any international travel outside of the U.S., requires prior approval by the  Office of International Programs.  
  • All employees who travel to destinations outside the United States must complete required approvals from the Office of International Programs and receive approval from the Office of Sponsored Programs, if required, before leaving on the trip. 
  • Prior to the travel, you may be required to complete a mandatory security briefing. 
  • Certain commodities taken outside of the U.S. may be subject to U.S. export controls. In particular, taking laptops, encryption products, data, technology, blueprints or other technical drawings to international conferences or visits to foreign institutions may fall under export controls. Consider taking a “clean” laptop on foreign travel. 
  • Any defense-related articles, services, and related technical data fall under the International Trafficking in Arms Regulations (ITAR) and require a license to be taken out of the U.S. Providing information about defense articles to foreign nationals is an export control violation. Exercise caution when presenting materials at international conferences or when visiting foreign institutions as you may be personally liable for any such violations. 
  • Be aware that the U.S. Customs and Border Protection Agency is authorized to search and retain electronic devices and potentially copy information from the devices. When traveling abroad, make sure you leave a copy of any data on your electronic devices in the U.S. in case the device is lost during inspection. 

1Electronic Code of Federal Regulations (e-CFR): Title 15. Commerce and Foreign Trade. Subtitle B. Regulations to Commerce and Foreign Trade. Chapter VII. Bureau of Industry and Security, Department of Commerce. Subchapter C. Export Administration Regulations. Part 734. Scope of the Export Administration Regulations. Section 734.8. “Technology” or “software” that arises during, or results from, fundamental research. (https://www.law.cornell.edu/cfr/text/15/734.8; accessed on April 14, 2019)