Content in progress

This page provides information on Norwegian export control, the responsibilities that rest on NTNU, and information about what is considered as sensitive knowledge.

Norsk versjon - Eksportkontroll

Topic page: Information security | The research process | Emergency planning

Export control and its purpose

The Ministry of Foreign Affairs (UD) is responsible for the Norwegian export control. The export control ensures that strategic goods, services, and technology from Norway are not exported in breach of obligations under international law or Norwegian security and defense policy. The export control also aims to prevent Norwegian goods, services, and technology from contributing to the spread of weapons of mass destruction (WMD: nuclear, chemical, and biological weapons) and their means of delivery (especially ballistic missiles).

Strategic goods are defined as weapons, ammunition and other military materiel and civilian goods that may have military utility or that may be used in terrorist acts, as well as associated technology and services. The term technology also includes intangible technology, including knowledge. This means that the higher education sector is also bound by the regulations, as we may have a lot of sensitive knowledge and technology in our subject areas and activities.

Export of knowledge occurs when the knowledge is transferred or made available to non-Norwegian citizens. This means that NTNU often must assess whether there are restrictions on our activities in accordance with the export control regulations.
In its annual threat assessments, the Norwegian Police Security Service (PST) describes how foreign states may operate to gain access to sensitive knowledge and technology. The PST’s threat assessment also highlights that Norwegian research and educational institutions will be exploited for illegal knowledge transfer.

We recommend that employees at NTNU who make assessments related to export control read the threat assessment for information on which countries are of particular concern. See PST’s threat assessment for 2024.

Our responsibilities

UD has, together with the Ministry of Education and Research, made guidelines for the higher education sector for control with knowledge transfer, see Retningslinjer for kontroll med kunnskapsoverføring. In these guidelines it is made clear that it is our own responsibility to assess the sensitivity of our knowledge and technology. It is also our own responsibility to ensure that the export control regulations are complied with when employing foreign nationals, when admitting foreign students within certain subjects, and by other knowledge transfer. Therefore, we must ensure that our departments map their own potentially sensitive areas, and that the export control regulations are complied with in relevant processes and activities.
Export control and illegal transfer of knowledge may be relevant to consider in, among others, these processes:

• Recruitment
• Guest stays
• Institutional collaborations
• One-on-one collaborations
• Sharing arenas where knowledge is communicated, for example, conferences

Licences, prior authorization, and work and residence permits

To comply with the export control regulations, we must apply for license from UD before knowledge transfer can legally take place to citizens from certain countries. Obtaining a license gives prior authorization from the Ministry for the sharing of knowledge.

According to the wording of the Export Control Act, it is considered an export as soon as the knowledge is transferred to a non-Norwegian citizen. The wording thus implies that we must apply for a license from UD in all cases where the knowledge is made available to non-Norwegian citizens. However, according to UD’s guidelines for control of knowledge transfer, the legislation is not meant to be practiced that strictly. According to the guidelines the regulations will primarily apply to citizens from countries subject to export restrictions, or from countries where there is justified suspicion or concrete information about activities related to development and use of WMD.

This, however, means that there is no fixed list of countries we can rely on when determining whether the transfer of knowledge may be in violation of regulations or not, and whether tit requires a license or not. The list of sanctioned countries is absolute, but we must also make specific assessments in each case concerning citizens from countries other than the sanctioned ones. For assistance with such assessments, NTNU’s central contact point can be contacted, see contact information further below.

Applications for licenses and prior authorization are submitted through UD’s portal for electronic applications for licenses. E-license can also be used for general inquiries about export control. Please contact NTNU’s central contact point for assistance with submitting applications or inquiries.

We also refer to UD’s list of four groups of countries, which you can find here (in Norwegian): Lisenstyper og landgrupper - regjeringen.no

Note that for citizens from Iran or with Iranian connections, license or prior authorization must always be applied for in order to be able to use equipment, technology or knowledge that is listed in the annexes to Iranforskriften (the iran regulation). This is an extension of the export control regulations.

Read more about exports to Iran at Regjenringen.no (in Norwegian).

NB: The Directorate of Immigration (UDI) is responsible for processing applications from foreigners who want to visit or live in Norway. Approval of work and residence permits is governed by other legislation and is not part of the scope of the export control regulations. This means that a non-Norwegian citizen can be granted a work and residence permit based on a signed employment contract with NTNU or on a letter of invitation, but UD may still refuse a license or prior authorization that may be necessary for the person concerned to be able to carry out the work.

Therefore, it is important that license or prior authorization from UD is granted before an employment contract is signed. Make sure to contact a person responsible for export control procedures as early as possible if a candidate is from a country that is covered by the export control regulations. In this manner we can perform export control assessments early in the process, so that the recruitment process is not unnecessarily delayed.

How is sensitive knowledge assessed?

Several criteria play a role in how the sensitivity of the various areas of knowledge and technology are assessed. The starting point for the assessment is the items lists of goods that are directly linked to the export control regulations, and appendixes that are linked to separate sanctions regulations, such as the Iran regulations.

Goods, services, and technology that are covered by the export control regulations are divided into two main categories:

• Defense-related goods (include technology intended for military purposes)
• Dual-use goods (include technology that is primarily civilian, but which may also have military utility, so-called dual-use potential)

See UD’s website for information about the lists (in Norwegian). Also, see this form (in Norwegian) for a brief introduction on how to read the items lists.

Even if we conclude that a particular type of knowledge or technology does not need a license under the items lists and does not require prior authorization related to goods specified in annexes to sanctions regulations, it is still necessary to assess whether it might be subject to a license according to the “catch all” provision.

See UD’s website for information about the «catch all» provision (in Norwegian).

For NTNU, it is mainly the dual use items in list II that must be assessed. The annexes to the various regulations in sanctions apply to persons from sanctioned countries. In addition, it is usually necessary with assessments related to the “catch all” provision. Sensitive knowledge and dual-use items are often associated with equipment, materials and technology found in laboratories.

According to UD, the sensitive knowledge and technology are most likely to be found in these specified subject areas:

• Life sciences, including biotechnology
• Biochemistry
• Chemistry, including chemical engineering
• Physics, including nuclear physics
• Aviation and aviation technology
• Mechanical engineering
• Materials science and engineering
• Cybernetics
• Medicine/veterinary science
• Mathematics

This list of subject areas is not exhaustive. It is important to clarify that in general we must be alert when it comes to citizens from countries to which there, according to the threats assessment, are legitimate concerns.

To get qualified assessments of the possible dual use potential, one must involve the academic staff. The academic staff usually know the most about the relevant subject areas and the potential of application of the knowledge and technology, beyond their defined purpose. The laboratory managers are usually the best at understanding the descriptions in the item lists, and how they may be linked to the laboratory instruments.

This form (in Norwegian) must be filled in when assessing whether a subject area with its technology and knowledge are covered by the export control regulations. The form should be completed by academic staff, and when completed sent to NTNU’s central contact point for further assessment.

Information and research data in areas of sensitive knowledge and technology must be classified as confidential in NTNU’s classification levels (in Norwegian), and treated accordingly.

More information

• The council for societal security and emergency preparedness (Beredskapsrådet) has created a topic page on export control in the knowledge sector (in Norwegian)
• The European Commission has provided a guide in English: EU compliance guidance for research involving dual-use items

Contact

NTNU’s point of contact for help

• Central contact point at NTNU: Marie Sundstrøm, Legal Adviser, Section for security and preparedness
• IV, IE and NV follow their own internal procedures. Contact HR at your own department or faculty if you have any questions.

Ministry of Foreign Affairs, Section for Export Control

For questions related to assessing technology and knowledge, questions about export control regulations, and questions about territories, arms embargoes and E-lisens (e-licensing system for export control).

• Telephone: 23 95 06 50
• Email: for.eksportkontroll@mfa.no

Norwegian Police Security Service (PST)

For advice and assistance in preventive work, on threats, and questions about possible concerns.

Inquiries to PST can be made through NTNU’s central contact point.

• PST Trøndelag, telephone: 738 99 090
• PST Innlandet, telephone: 625 39 000
• PST, Møre og Romsdal, telephone: 701 18 700
• Email: post@pst.politiet.no