Export Control

Basic principles: The Four Export Control Regimes and Switzerland’s Role

Switzerland participates in several international regimes that govern the export, import, and transit of goods. These regimes aim to prevent the proliferation of weapons of mass destruction (WMD), conventional arms, sensitive military technologies, and dual-use items. Member states agree on detailed lists of goods subject to national controls, including physical goods, software, and both tangible (technical documentation) and intangible technologies (technical assistance).

Responsabilities 

Impact on EPFL Staff and Faculty

Unit heads and project leaders are responsible for ensuring compliance with laws and internal regulations on export control.

In the course of their work at EPFL, staff and faculty may need to transfer information, research results, demonstrators, prototypes, or software outside Switzerland (export). These items may fall under export control legislation, particularly if they involve dual-use goods or sensitive technologies.

Transfers may occur in various contexts, such as:

• Research or service agreements (with industrial partners, public institutions, or non-profit organizations);
• Technology transfer agreements (patent or software licenses, transfers of inventions or intellectual property rights).

It is important to note that informal exchanges without a contractual basis (discussions, emails, presentations, etc.), or even those covered by a confidentiality agreement (NDA), may be considered exports under the law and therefore require authorization or declaration.

Therefore, before transmitting any non-public data or knowledge abroad, one should:

• Check whether the items appear on the control lists in the Goods Control Ordinance (OCB)
• Consult the relevant annexes on the State Secretariat for Economic Affairs (SECO) website
• And, if you have any questions or doubts, contact the TTO (Export Control Officer) or Legal Affairs at: [email protected]

International Collaborations

Special care is required when working with foreign partners, particularly U.S. entities. U.S. laws (e.g., EAR, ITAR) may restrict access to certain technologies based on nationality, regardless of location.

It is therefore essential to ensure compliance with applicable foreign laws before entering into any collaboration.

Swiss Legal Framework

Export control in Switzerland is governed by the following laws and ordinances:

– Federal Act on War Materiel (War Mar Act, WMA,RS 514.51) – (DE / FR / IT / EN)

Regulates the manufacture and transfer (import, export, and transit) of war material, as well as its brokerage and trade. War material refers to weapons, ammunition, military explosives, and equipment specifically designed or modified for combat engagement or for conducting combat operations. War material also includes spare parts and assembly components, even if only partially machined, when it is clear that they cannot be used in the same form for civilian purposes

– Federal Act on the Control of Dual-Use Goods, Specific Military Goods and Strategic Goods (Goods Control Act, GCA, RS 946.202) – (DE / FR / IT / EN)

It governs dual-use goods (civil and military) as well as specific military items. The GCA notably provides that:

• The export of goods, components, software, technologies, and information of dual-use nature. Dual-use items include goods, technologies, and software that can be used for both civilian and military purposes. Their export generally requires authorization from SECO.
• The export of goods, components, software, technologies, and information known
• or suspected – to be intended for the development, production, or use of nuclear, biological, or chemical weapons (NBC weapons), or for delivery systems (rockets, missiles, drones, etc.) designed to deploy NBC weapons, is subject to a prior declaration requirement with SECO.
• A so-called “catch-all” clause stipulates that even items which are not listed, may require authorization if there is a risk they could be used in WMD programs or their delivery systems (missiles, rockets, drones, etc.).

– Federal Act on the Implementation of International Sanctions (Embargo Act, EmbA, RS 946.231) – (DE / FR / IT / EN)

Allows the Federal Council to impose economic sanctions, trade bans, or financial restrictions.

– Ordinance on War Materiel (War Materiel Ordinance, WMO, RS 514.511) – (DE / FR / IT / EN)

– Ordinance on the Control of Dual Use of Goods, Specific Military Goods and Strategic (Goods Control Ordinance, GCO, RS 946.202.1) – (

 Includes control lists:

• Annexes 1 & 2: Dual-use goods
• Annex 3: Specific military goods
• Annex 7: Countries eligible for general export licenses.

– Ordinance on the Export and Brokerage of Goods for Internet and Mobile Communication Surveillance (OSIC, RS 946.202.3) – (DE / FR / IT)

– Safeguards Ordinance (SaO, SR 732.12) – (DE / FR / IT / EN)

Further informations 

• SECO: Export controls and sanctions
• SECO: Sanction measures
• SECO: Legal basis
• SECO Factsheet: Basic principles of export control

Key Takeaways – The Five Essentials of Export Control at EPFL

1. Any transfer outside of Switzerland of goods, software, or non-public knowledge may constitute an export.
2. Dual-use or military goods require SECO authorization or declaration.
3. Even informal exchanges (emails, discussions, presentations) may be subject to control.
4. EPFL’s general license does not cover all cases – check annexes and exclusions.
5. If doubts persist, contact the TTO (Denis Beyeler – Export Control Officer) or Legal Affairs (Melissa Magnenat) before any transfer.