Export Control

High Performance Computing is a dual-use good

Supercomputers are defined as dual-use goods, as they can be used for both, civil and military purposes. Their export and any “technical assistance” through their use are principally subject to export control laws, specifically the German foreign trade law (Deutschen Außenwirtschaftsrechts) and the EU regulation No. 2021/821 (that governs the export control of dual-use goods).

In addition, there are embargo sanctions against specific countries or persons.

This legal framework may result in restrictions on the use of supercomputers in relation to certain countries or groups of people.

Providing access to the use of computing resources may be considered prohibited or subject to authorization under export control law if the use is specifically related to military use.

Effects for Usage

Therefore, access to GWDG HPC resources is restricted for persons whose country of origin is listed on the sanction map.

In addition, the usage is restricted if users are located in embargoed countries and intend to use the HPC resources.

The computing projects are classified as follows with regard to their civil and/or military use:

  • Civil
    • Scientific work that produces knowledge, products or technologies that have exclusively civilian applications.
  • Dual-use
    • Scientific work that has the potential to generate knowledge, products or technologies that could be directly misused by third parties to cause significant harm to human dignity, life, health, freedom, property, the environment or peaceful coexistence (so-called dual-use research of concern).
  • Military
    • Scientific work that produces knowledge, products or technologies that are specifically related to weapons of mass destruction (NBC weapons) and their delivery systems, weapons of war, armaments, missile technology, and end uses relevant to armaments.

If the computing project is affected by restrictions a consent provided by the BaFa can be handed in in order to clear restrictions or get computing access or at all.

The PI of the project is responsible for the compliance of her/ his colleagues with these terms and for the truthfulness of their statements (see also Terms of Use).

Depending on home country and project classification the following restrictions might apply:

Check, if the user’s home country is on embargo list (see the sanctionmap).

  • if country with no embargo
    • user will be added
    • without restrictions
    • project classification has no influence
  • if country is on embargo list
    • project classification “civil”
      • user will be added
      • user has limited computing access
    • project classification “dual-use”
      • user will not be added
      • user block can be canceled by the PI by providing a BaFa consent
    • classification “military”
      • user cannot be added to project

If the home country of the PI is under embargo, the embargo consequence is enforced on the entire project.

  • if classification “civil”
    • hpc usage possible, with respective restrictions
    • if higher quota is requested, a BaFa consent is necessary
  • if classification “dual-use”
    • a BaFa consent is necessary
  • if classification “military”
    • a BaFa consent is necessary

For further information please contact your export control position of your institution. For employees of the Georg August University of Göttingen it is the Law and Foundation Department.

Call to Action for all Users of GWDG HPC Resources

  • Each user must login to the project portal and select her/ his home country.
  • In addition, the PI must classify all her/ his computing projects (see above).
    • This is necessary for all existing as well as upcoming projects.
    • Please check if there are any indications in your ongoing and planned research projects that your research results could produce knowledge, products, or technologies that could be immediately misused for significant harmful purposes (Dual Use Research of Concern, DURC).

Changes in the Project Portal

Changes will be implemented during 2025 successively.

  • In the user account settings the user’s citizenship is recorded.
  • If applicable, restrictions will be recorded in the respective computing project and, in order to protect privacy data, will be visible only to the PI and affected users.
  • The section “Unclassified projects” provides a list with all projects that are not yet classified by the PI.