Export control and its purpose
The Norwegian Agency for Export Control and Sanctions (DEKSA) is responsible for Norwegian export control. Expert control ensures that strategic goods, services and technology from Norway are not exported in violation of international obligations or Norwegian security and defence policy. Export control aims to prevent Norwegian goods, services and technology from contributing to the proliferation of weapons of mass destruction (nuclear, chemical and biological weapons) and their delivery systems, particularly ballistic missiles.
Strategic goods include weapons, ammunition and other military material, as well as civilian goods that could have military applications or be used in terrorist acts, along with related technology and services. The term technology also encompasses intangible technology, including knowledge. Knowledge export occurs whenever knowledge is transferred or made available to non-Norwegian citizens. This means that we often have to make assessments of export control at UiA.
In its annual threat assessments, the Norwegian Police Security Service (PST) discusses how foreign countries operate to gain access to sensitive knowledge and technology. In 2025, it is indicated that Norwegian research and educational institutions will be exploited for illegal knowledge transfers.
UiA's responsibility
The Ministry of Foreign Affairs (MFA), in collaboration with the Ministry of Education and Research, has developed guidelines for controlling knowledge transfer within the higher education sector. These guidelines emphasise that institutions themselves bear the responsibility for assessing the sensitivity of their knowledge and technology and ensuring compliance with export control regulations. This responsibility pertains to various situations, including hiring foreign nationals, admitting international students in certain subject areas, and other forms of knowledge sharing. At the University of Agder (UiA), this means that each department must identify any sensitive subject areas and ensure export control regulations are adhered to in relevant processes and activities. Export control and illegal knowledge transfer may need to be considered in the following processes:
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Employments
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Visiting engagements
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Institutional cooperation
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One-to-one collaborations
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Platforms where knowledge is disseminated, such as conferences
Licences, work and residence permits
In order to comply with export control regulations, a licence must be obtained from DEKSA (Norwegian Agency for Export Control and Sanctions) before sensitive knowledge can be shared with individuals from certain countries. A licence is a prior authorisation that legally permits the transfer of knowledge.
Under the Export Control Act, sharing knowledge with someone who is not a Norwegian citizen is considered an export. The wording suggests that we must apply for a licence from DEKSA in all cases where the knowledge is to be made available to non-Norwegian citizens. However, according to the guidelines from MFA on controlling knowledge transfer, the legislation is not intended to be applied so strictly. The guidelines state that the regulations will primarily apply to citizens from countries subject to export restrictions or from countries where there is reasonable suspicion or concrete information about concerning activities related to the development and use of weapons of mass destruction.
For these countries, there is no definitive list beyond those that are sanctioned. For other countries, individual assessments must be made. The list of sanctioned countries is absolute, but specific assessments must also be carried out for each case concerning citizens from countries other than those sanctioned. For assistance with such assessments, contact ais@uia.no.
Applications for licences and prior authorisation are made via DEKSA's electronic portal, E-lisens, which can also be used for general inquiries about export control.
Note that for persons with Iranian nationality or connections, assessments must be made against both the regulation 'Iranforskriften' and Control List II.
More about exports to Iran - government.no (in Norwegian)
NB: The Norwegian Directorate of Immigration (UDI) processes applications for residence and work permits in Norway. This is regulated under different legislation than export control. This means that an individual may be granted a residence permit based on an employment agreement with UiA, but still be denied a licence from DEKSA.
It is therefore very important that any licence from DEKSA is granted before the employment agreement is signed. Ensure you contact the case officer for export control as early as possible if a prospective candidate is from one of the countries covered by export control legislation. This allows you to make export control assessments early in the process, potentially avoiding delays. However, it is recommended to delay entering into binding agreements until you have received a response to the licence application from DEKSA.
How to assess sensitive knowledge?
Sensitivity is assessed based on the control lists annexed to export control regulations and additions to the sanctions regulations. There are two main categories for items, services, and technology subject to export control regulations:
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Defence-related goods (including technology intended for military purposes)
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Dual-use goods (including technology primarily for civilian use, but which may also have military utility, known as dual-use potential)
In cases where it is concluded that a specific type of knowledge or technology is not subject to licensing under Control Lists I, II or III, or will require prior authorisation related to goods in sanction regulation attachments, it must be assessed whether the knowledge or technology might still be subject to licensing under the "catch all" clause.
More about the "catch all" clause - government.no (in Norwegian)
For UiA, Control Lists II and III, which pertain to dual-use goods are primarily relevant. The attachments to various sanction regulations apply in the case of citizens from sanctioned countries. Additionally, assessments related to the "catch all" clause are generally necessary. Sensitive knowledge and dual-use goods are often associated with equipment, materials and technology commonly found in various types of laboratories.
The application of the regulations on knowledge transfer requires educational institutions to conduct specific assessments of PhD Research Fellows in the subject areas listed below:
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Life sciences, including biotechnology
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Biochemistry
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Chemistry, including chemical process technology
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Physics, including nuclear physics
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Aviation and aerospace technology
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Mechanical engineering
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Materials technology
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Cybernetics
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Medicine/veterinary science
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Mathematics
Additionally, particular vigilance must be exercised for master's programmes, especially those that involve the following technology areas:
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Life sciences, including biotechnology
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Biochemistry
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Chemistry, including chemical process technology
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Aviation and aerospace technology
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Physics, including nuclear physics
The list of subject areas is not exhaustive, and it is important to remain vigilant when hiring or engaging individuals from countries associated with specific concerns.
To obtain qualified assessments of possible dual-use potential, we must involve academic staff who are most familiar with the relevant subject areas and the broader applications of the knowledge and technology beyond the defined purpose. Laboratory managers are usually best positioned to understand the designations on control lists and how they relate to the characteristics of laboratory instruments.