Export control of dual-use items

Dual-use items are goods and technologies that may be used for both civilian and military purposes. Export control is a term used to describe the laws and regulations that prohibit strategically, sensitive products from falling into the wrong hands.

For Karolinska Institutet it is important to prevent the misuse of academic knowledge for military purposes or for illegal weapons of mass destruction programmes.

Dual-use items may not be exported outside the EU without a license from the Swedish Inspectorate of Strategic Products (ISP). In some special cases, transfer within the EU of such items also require a license. KI must ensure that all handling of dual-use items is carried out in accordance with applicable export control laws and regulations.

What kind of research at KI is affected?

The goods and technologies classified as dual-use items are listed and described in Annex I of the EU Council Regulation No 2021/821 (EU Dual-use Regulation). The list can be found under Links further down this page. The controlled items are divided into 10 different categories and include:

Category 0 Nuclear materials, facilities and equipment
Category 1 Special materials and related equipment
Category 2 Materials Processing
Category 3 Electronics
Category 4 Computers
Category 5 Telecommunications and "information security"
Category 6 Sensors and lasers
Category 7 Navigation and avionics
Category 8 Marine
Category 9 Aerospace and Propulsion

At KI, examples may, for example, be specific human or animal pathogens and toxins (category 1), certain chemicals (category 1), advanced computers (category 4) or instruments (category 6). The term dual-use item also includes technologies for the development, production or use (including software) of goods specified in the above-mentioned annex.

What is export?

Export refers to a transfer out of the European Community, and that includes:

  • Physical transport
  • Transmission by electronic media
  • Oral transmission of technology

Transfer of technology using electronic media (for example via e-mail or via the Internet) to a destination outside the EU is defined as export. Scientific publication as well as oral transmission of technology is also covered by the export control regulations.

Export control may be relevant for KI:s researchers in, for example, international research projects where it is important that the responsibility for possible export licenses are regulated in the agreements. Another example is when KI employees participate in international conferences. When assessing the risk on international partnerships, it is important to know whether PDA will be handled within the collaboration.

Anyone who exports products and/or technology from the country is obliged to find out if these are classified as dual-use items. Even if a license is not required for transfer within the EU, there is an obligation to provide information if it concerns dual-use items.

Export control coordinator at KI

An export control coordinator at the Safety and security unit supports researchers in classifying products and applying for export licenses. Each department with research affected by the export control regulations must have local instructions for export control and handling of dual-use items.

These departments must also have a local export control representative who is trained in export control rules, who supports internally in classification and who is the contact person for KI's central export control coordinator. It is the research group leader who must assess whether a research project includes a dual-use item and, when exporting, make an assessment of whether an export license is needed.

The export control coordinator at the Safety and security unit must be informed about possession of dual-use items and before planned export of dual-use items. Appropriate security measures that prevent unauthorized access to dual-use items (goods and technology) shall be applied at the department.


KI needs each year to declare to ISP the import and export of certain chemicals that are subject to declaration requirements under the United Nations Chemical weapons convention. This applies to chemical weapons  and certain chemical precursors that can be used for the manufacture of chemical weapons.

A declaration on dual-use items sold must also be submitted annually to the ISP. If contract research results in a sold dual-use item, this must be included in the declaration, therefore the export control coordinator at the Safety and security unit needs to be informed of this.


To prevent exporters from deliberately trying to circumvent the law's intention, there is also a so-called “Catch-all clause” in the EU Dual-use Regulation.  This clause means that if the exporter is aware of that the product / technology may be used for weapons of mass destruction, it is subject to export control even if the product is not listed in Annex I.


As a rule, exports are permitted unless there are special reasons to the contrary. Sometimes, however, there are sanctions against certain countries, companies or individuals, whereby opportunities for cooperation with them may be limited. In Sweden, we follow the sanctions decided by the UN, the EU and the OSCE.


Export control coordinator: Margaretha Vickes
Tel: 08 - 524 865 64
Email: exportkontroll@ki.se

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