Procurement – Office of Research Compliance

When purchasing manufactured items (i.e., equipment, software, technology, information, or other similar goods), through UH and/or RCUH procurement activity, the PI should review the vendor’s sales information to determine if the goods are subject to either ITAR or EAR.

Please have the vendor complete the form if they have not already provided the ITAR or EAR classification. UH PI must sign the completed vendor form, and forward to the OEC before the OEC makes an export controls determination.

Export Controls Classification Certification form

To the greatest extent possible, the University of Hawai‘i, Office of Export Controls (“OEC”) relies on manufacturers to provide export control information of manufactured items obtained through procurement activity. To facilitate this, the OEC has developed and implemented the Export Controls Classification Certification form, which is used to accurately identify and classify items being procured, and assist PIs in determining what, if any, export controls need to be considered in order to comply with U.S. export regulations.

The reasons to require the Export Controls Classification Certification form be executed by the vendor includes, but is not limited to:

The vendor includes export control clause or language in their contract/purchase agreement, or purchase quote;
The PI believes the product is subject to either ITAR or EAR, and is enumerated on the USML or CCL; and/or
If foreign nationals will have access to the item and the PI is unsure if the product is subject to either ITAR or EAR, and is enumerated on the USML or CCL.

Federal ban on drones from certain foreign entities

Effective December 22, 2025, federal regulations under FAR 52.240-1 and DoD 1260H prohibit the procurement or use of drones manufactured by restricted foreign entities, such as DJI and Autel, in federally funded research. These mandates are designed to protect national security and sensitive research data from foreign influence. Before purchasing or operating any drone for a federal project, you must verify the manufacturer against the current SAM.gov prohibited lists and confirm your specific award terms. Failure to comply may result in the loss of federal funding, contract termination, or legal penalties.