Export Control

High Performance Computing is a dual-use good

Supercomputers are classified as dual-use goods, indicating their potential for application in both civilian and military contexts. The exportation of goods and the provision of “technical assistance” through their use are subject to export control laws, specifically the German Foreign Trade Law (Deutschen Außenwirtschaftsrechts) and the EU regulation No. 2021/821, which 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.

Our joint legal obligation is to prevent misuse that would cause significant harm to human dignity, life, health, freedom, property, the environment or peaceful coexistence. Any researcher and associate are obliged to contribute in order to implement the legal requirements.

Call to action for all users of GWDG HPC resources

To comply with export control regulations, the following changes were implemented in the HPC Project Portal:

  1. Each user must enter their nationality in the project portal. It is recorded in the account settings.
  2. Based on the scientific work being done, the Principal Investigator (PI) of each project must classify it as either “basic research”, “civil,” “dual-use”, or “military”.
  3. In addition to the already existing project description, the PI must add a short justification of their project’s classification (“basic research”, “civil”, “dual-use”, “military use”).

We understand that these changes are inconvenient. These actions are necessary in order to meet our legal obligations. We aim to be as accessible as possible and enable external partners to the extent permitted by the sanctions.

Project classification

Each compute project must be classified into one of four categories.

  • Basic Research
    • Scientific work that is oriented towards new and fundamental insights with no focus on immediate practical application and commercial benefits. The work should also not focus on specific processes and products to be marketed. The work is not externally financed by industry. The Technology Readiness Level (TRL) is not more than 1-3.
  • 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 weaponry of any kind, including weapons of mass destruction (nuclear, biological, and chemical weapons) and their delivery systems, weapons of war, armaments, missile technology, and end uses relevant to armaments.

Please check if there are any indications in your ongoing and planned research projects that your results could produce knowledge, products, or technologies that could be immediately misused for significant harmful purposes (Dual Use Research of Concern, DURC).

Effects for usage

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

If a project is classified as “basic research”, it falls outside the scope of EU export control regulations. Therefore, a user’s nationality is irrelevant and does not lead to restrictions if applicable.

For any other classification, we check if the user’s home country is on an embargo list (see the sanctionmap).

  • if country without embargo
    • no restrictions
    • project classification has no influence
  • if country with embargo
    • project classification “civil”
      • user has limited computing access
    • project classification “dual-use”
      • user is denied computing access
    • classification “military”
      • user is denied computing access

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

  • if classification “civil”
    • computing access with respective restrictions for all project members
  • if classification “dual-use”
    • denied computing access for all project members
  • if classification “military”
    • denied computing access for all project members

If the home country of a project member is under embargo, this user cannot be changed to the role Delegate.

The restrictions are as follows:

  • Users from China are not allowed to have GPU access.
  • Users from embargo countries (other than China) have limited computing access of maximal 300.000 core hours.

In the event that a project member is subject to restrictions, the Principal Investigator (PI) or the Delegate have the authority to remove such restrictions from a project member through the HPC Project Portal. This process necessitates the submission of an explanation, which is documented in the project’s action log.

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

When changes to the sanctions map occur due to political decisions and additional countries are placed under embargo, or if embargoes are lifted, we will update the respective database in the Project Portal. This update has an immediate effect on access to compute resources in general and other potential limitations (like use of GPUs).

Please contact the export control position at your institution for more information. For employees of the Georg August University of Göttingen, this is the Law and Foundation Department.

Support

As this is a sensitive topic, our support team will be on hand to address your questions and provide you with the best possible assistance. To contact us, please write an email to hpc-support@gwdg.de.

FAQs

Please note: This is no legal advice. We are not liable for any legal claims.

I need support, who can I contact?

For any concern, please write an email to our support team (hpc-support@gwdg.de). They will be on hand to address your questions and provide you with the best possible assistance.

How can I see what countries are affected?

Please check the sanction map https://sanctionsmap.eu/#/main to learn which countries are affected by embargoes.

Do I really have to do this?

Yes. Any researcher and associate is obligated to contribute in order to implement the legal requirements. Our joint legal obligation is to prevent misuse that would cause significant harm to human dignity, life, health, freedom, property, the environment or peaceful coexistence.

The project classification is not only necessary to get access to high performance computing resources but also when you are in an international exchange during your research activities. In a dual-use project, even advising people can be considered as giving technical assistance and therefore might have to be prevented.

What do I need to do?

Visit the project portal.

  1. Each user must enter their nationality in the Project Portal.
  2. Each PI must classify all her/his projects in the project portal in either “civil”, “dual-use”, or “military” based on the resulting scientific work.
  3. In addition to the already existing project description, the Principal Investigator (PI) must explain the project’s classification (basic research, civilian, dual-use, military use).

My project is already running. What do I have to do?

The same regulations apply to new and ongoing projects. See “What do I need to do?” for the required actions.

What do I need to consider as a PI when adding persons to my computing project?

Check if the home country of the person you want to add to your computing project is on the embargo list (see the sanctionmap).

If it is a country with no embargo, the user will be added, there will be no computing restrictions. The project classification has no influence.

If it is a country with an embargo, the project classification is considered. For civil projects the user will be added, but has limited computing access. These limitations can be canceled by the PI in the project portal. For dual-use and military projects the user will be added to the project, but has no computing access. This block can be canceled by the PI in the project portal.

How can I unban restrictions?

Only the PI and the Delegate can unban restrictions of project members in the project portal by giving an explanation. This explanation will be logged and can be viewed any time. Keep in mind that the PI takes the full responsibility. The PI and Delegate cannot unban themselves. For this write a support ticket (hpc-support@gwdg.de).

My home country is on the embargo list but I am living in Germany for several years. What applies to me?

When a user (in every role) has lived in Germany for at least five years they can be considered a resident and possible restrictions do not apply.

If you are a PI please write a support ticket (hpc-support@gwdg.de) and inform us. The restrictions will then be cleared by our support team. As a project member, you can contact either your PI or the support team. Both can clear your restrictions.

I want more information. Where can I find them?

What are exemplary research projects and their classification in civil, dual-use, and military?

Exemplary civil research projects* Medicine and Biology * Basic research leading to the development of vaccines against diseases such as measles, polio, or malaria to protect and improve public health. * Research into the causes and treatment of neurodegenerative diseases such as Alzheimer's or Parkinson's that is focused on improving patients' quality of life. * Analyzing microorganisms in freshwater lakes or oceans helps to monitor the health of ecosystems and ensure water quality. * Social sciences and humanities * Studying historical city maps and analyzing how cities have changed over the centuries can contribute to the preservation of cultural heritage and civil urban planning. * Research of rare or extinct languages to preserve cultural heritage and document human diversity. * Studies on optimizing learning methods, early childhood education, or the integration of students with disabilities to improve the education system. * Engineering * The development of smart prostheses and exoskeletons that enable people with physical disabilities to walk again or grasp objects to improve the quality of life for those affected. * The development of more efficient solar cells, wind turbines, and energy storage systems to provide a sustainable energy supply for households and industry.
Exemplary dual-use research projects* Life Sciences * In 2012, it became known that researchers had manipulated the H5N1 avian influenza virus so that it could be transmitted through the air in ferrets. The aim of the research was to better understand how the virus could mutate in order to predict a possible pandemic. However, the result, a genetically modified, transmissible virus variant, carries the risk of being misused as a biological weapon. * Artificial intelligence (AI) * An algorithm that serves civilian purposes, such as detecting tumors in X-ray images or navigating autonomous vehicles, can also be used in military contexts. For example, the same algorithm could be trained to identify strategic targets, specific vehicles, or individuals in satellite images. * Research aimed at automatically finding vulnerabilities in software in order to improve cybersecurity can also be exploited by cybercriminals or state actors. Such a tool could be used to prepare attacks on critical infrastructure. * Chemistry and material sciences * High-performance carbon fibers are used in the civilian sector in the manufacture of sports equipment and lightweight aircraft components, and in wind energy to stabilize turbine blades. However, their high strength and low weight also make them ideal for the manufacture of rocket casings and military drones. * Research into new catalytic nanomaterials can dramatically improve the efficiency of industrial processes such as petrochemicals. However, the same findings could also be used to optimize the production of fuels for military purposes or for the synthesis of chemical warfare agents. * Digital Humanities * Research that analyzes historical documents using AI methods to identify social or political patterns can provide valuable insights into the past. However, this knowledge and these algorithms could also be used by intelligence agencies to monitor vast amounts of data from social media or communication networks and predict behavior patterns. * Engineering * Computer-controlled (CNC) machine tools are used in the civilian production of automotive parts, medical devices, and aircraft components. However, their precision also makes them ideal for manufacturing rocket parts, submarine components, and other components for military equipment. * Small drones can be used by hobbyists for photography or by farmers to monitor fields. With a few adjustments, they can be used for military reconnaissance purposes or as carriers for small explosive devices. * Medicine and biology * CRISPR enables scientists to precisely modify genes in order to cure diseases or make plants more resistant. However, the same technology could also be misused to make pathogens such as viruses more deadly or transmissible, or to modify human genes for non-therapeutic purposes. * Psychology * Research into how rumors or disinformation spread on social networks can be used to develop strategies against fake news and promote public health. However, the same findings could also be used to create targeted propaganda campaigns to destabilize societies or for psychological warfare. * Agriculture sciences * The development of genetically modified crops that are resistant to pests and deliver higher yields can facilitate global food security. However, knowledge about the genetic weaknesses of crops could also be used to develop specific biological weapons against a country's food supply. * Forestry * Technologies that use satellite or drone imagery to monitor the health of forests are essential for climate protection and sustainable forestry. This data could also be used for military purposes to identify camouflaged positions, troop movements, or secret production sites in forested areas. * Chemistry * Research into new nanoparticles could lead to innovative medical treatments (e.g., targeted cancer therapy) or more efficient catalysts for energy production. However, the same materials could also serve as carriers for chemical warfare agents or be used in camouflage technology to produce invisible coatings for military vehicles. * Earth sciences * Monitoring earthquakes and volcanic activity helps to detect natural disasters early on and protect civilians. However, the same seismic measuring devices are also capable of registering the detonation of underground nuclear tests, thus helping to monitor international arms control agreements or serving as a tool for armament. * Mathematics and computer science * Basic research in cryptography serves to ensure secure communication and transactions on the Internet (e.g., online banking). However, the knowledge gained from this research can also be used to develop unbreakable encryption that could be used by terrorist organizations or criminal networks for their communications. * Mathematical models for analyzing social networks can predict the spread of disease in a population or optimize marketing strategies. The same methodology could be used by intelligence agencies to map terrorist networks or find vulnerabilities in an adversary's communication structures. * Law and economics * Analyzing legal gray areas and developing standards for cyber warfare should strengthen international stability. However, the knowledge gained about these gaps can also be used by states or hacker groups to carry out cyber attacks that are difficult to prosecute legally. * Research into global trade flows and supply chains helps to strengthen the resilience of the economy in times of crisis. However, knowledge about critical bottlenecks and dependencies can also be used militarily to deliberately weaken the economy of an enemy state. * Humanities and cultural studies * Studying how mass manipulation worked in the Third Reich or other totalitarian regimes helps us to recognize and combat totalitarian tendencies in the present day. However, the knowledge gained about the psychological mechanisms of mass communication could also be used by modern autocracies to influence public opinion. * Research on social and cultural dynamics in crisis areas helps peace researchers to better understand and resolve conflicts. The same insights are invaluable to the military in understanding the local population and planning operations in foreign cultures.
Exemplary military research projects* The development of missiles that fly at more than five times the speed of sound and are maneuverable is primarily aimed at evading enemy defense systems. Research in this area focuses on aerodynamics, new propulsion systems, and heat-resistant materials designed exclusively for this purpose. * Research into materials and designs that minimize the radar signature of aircraft, ships, or vehicles to make military units invisible to enemy sensors. * Research into systems that generate a strong electromagnetic pulse to disable electronic devices in a specific area is used exclusively for warfare, as it aims to destroy the enemy's communications, power grids, and control systems. * The development of robots or drone swarms capable of independently identifying, tracking, and attacking targets. * Research into the development of drugs or technologies that increase the alertness, endurance, or stress resistance of soldiers in combat situations has a clear military purpose. This ranges from research into substances that reduce fatigue to prosthetics that exceed the functionality of natural limbs. * While civilian Earth observation satellites are used for weather forecasting or climate research, military reconnaissance satellites are specifically designed for espionage. Their research focuses on extremely high-resolution optical or radar systems capable of detecting military installations and troop movements on the ground. * Research into sonar systems and acoustic sensors for detecting and tracking submarines. Although sonar is used in civilian shipping, military applications are much more specialized and designed to detect enemy vessels.