Export controls at the University of Göttingen

1) Responsibility

The University of Göttingen is an internationally oriented research and teaching institution with extensive academic partnerships, mobility programmes, externally funded projects and technology transfer initiatives. Research, teaching, knowledge and technology transfer, and international collaboration are central to its identity and public mission.

This international network also gives rise to a particular legal responsibility. The University of Göttingen Foundation is obliged to comply fully with all regulations governing foreign trade and export controls. This applies in particular to the provisions of the Foreign Trade Act (AWG), the Foreign Trade Ordinance (AWV), Regulation (EU) 2021/821 on dual-use items, EU and national embargo regulations, as well as accompanying security, human rights and sanctions-related requirements.

The University of Göttingen is aware that public universities form an integral part of national and supranational safeguards against risks relating to security, peace and human rights. Export controls therefore serve not merely to ensure administrative compliance with the law, but also to manage risks in a geopolitically sensitive environment. Compliance with these controls is therefore not a marginal issue, but an integral part of responsible university governance and institutional integrity.

2) Objectives of export control

Export controls pursue legitimate and compelling societal objectives. In particular, they serve

- to control and prevent the unauthorised transfer of goods, technologies, software, technical data and know-how that can be used for both civilian and military or repressive purposes (dual-use goods and technologies)

- to prevent the proliferation of nuclear, chemical, biological and radiological weapons, as well as their associated delivery and application systems

- to limit the accumulation of conventional armaments in regions of crisis, conflict and tension

- combating terrorism, state and non-state repression, and organised crime in connection with international flows of resources, technology and knowledge

- the protection of fundamental human rights, internal and external security, and the international legal order.

Export control addresses not only the physical movement of goods, but increasingly also intangible transfers, digital access, research collaborations, services, consultancy services, cloud-based infrastructures and personal mobility. These objectives guide the institutional self-image of the University of Göttingen.

3) Academic freedom and export control obligations

The University of Göttingen is fully committed to the freedom of research and teaching as enshrined in Article 5(3) of the German Basic Law. This freedom forms a cornerstone of academic work and the international cooperation that goes hand in hand with it.

At the same time, the Executive Board makes it clear that academic freedom does not constitute an exemption from the obligations regarding review, participation and authorisation under foreign trade or export control law. Research that is internationally networked may give rise to security-related risks. The University is required to identify, assess and manage these risks in accordance with the law.

Academic freedom and export control do not stand in a relationship of tension that allows for an ‘either-or’ choice. They are legal frameworks that must be balanced against one another in organisational and procedural terms. The aim is to effectively counter hostile use of research, unlawful technology transfer, circumvention and international proliferation without restricting open scientific exchange beyond what is legally required.

4) Export Manager and Export Control Officer

The Executive Board bears overall responsibility for the organisation of export controls at the University of Göttingen (excluding Göttingen University Medical Centre (UMG)). It appoints the President as the export control officer at management level, who assumes personal responsibility for compliance with export control regulations within the University.

In addition, an export control officer is appointed by the Executive Board. This person is responsible for the operational implementation of export controls in consultation with the export control officer as their direct superior, in particular the coordination of review processes, risk assessment, support for authorisation procedures and internal advisory services.

Both roles are provided with the necessary powers, resources and access rights by the Executive Board.

5) Statement of Commitment

The Executive Board of the University of Göttingen is expressly, unequivocally and permanently committed to complying with all foreign trade and export control regulations. This declaration serves as a binding standard for the institution’s actions.

The Executive Board ensures that export control is integrated systematically, structurally and effectively into the university’s decision-making, administrative and research processes. The aim is not ‘symbolic compliance’, but demonstrable effectiveness.

From the Executive Board’s perspective, compliance with export control requirements is the responsibility and obligation of all university stakeholders in research, teaching, administration and technical services. Every individual is required to examine relevant circumstances, address risks at an early stage, report incidents and adhere to established procedures. Deviations, circumventions or passivity are incompatible with this guiding principle.

This commitment forms the binding basis and the first building block for a university-wide (excluding University Medical Centre Göttingen (UMG)), systematically structured and continuously developed “Internal Compliance Programme (ICP) Export Control”. The Executive Board bears responsibility for its establishment, enforcement, monitoring and adaptation to changing legal and geopolitical conditions.