What technology courses require an exemption from the knowledge embargo, and how can I apply for an exemption?

Both the United Nations (UN) and the European Union (EU) require countries to ensure that knowledge related to nuclear weapons and missile technology does not fall into the hands of North Korea or Iran. Since 2014 there has also been a ban in place on providing goods and technology and technical assistance on dual-use goods and technology to Russia. Dutch universities and knowledge institutions have knowledge and expertise that could be used to produce nuclear weapons and delivery systems. For this reason, anyone who might come into contact with this knowledge (e.g. students, researchers and technical staff) must apply in advance for an exemption to the knowledge embargo. Without this exemption you are not allowed to start a course of study or a research project, or to work within these fields. You can apply for an exemption with the Ministry of Education, Culture and Science.

Sanctions

The UN requires countries to prevent specific knowledge about producing nuclear weapons and delivery systems (ballistic missiles) from ending up in the hands of North Korea, whether directly or indirectly. These UN sanctions also apply in the EU. The North Korea Sanctions Order 2017 (page in Dutch) sets out how these sanctions are applied in the Netherlands.

The EU also bans the transfer of any knowledge that can contribute to Iran’s ballistic missile programme (Council Regulation (EU) No 267/2012 of 23 March 2012 concerning restrictive measures against Iran). When reviewing applications for exemption from the knowledge embargo for North Korea, the Ministry of Education, Culture and Science uses the information supplied to also determine if there is any possible relationship to the Iranian ballistic missile programme. The sanctions also apply to certain forms of education and to assisting with or offering certain research projects. The Iran Sanctions Order 2012 (page in Dutch) sets out how the sanctions are implemented in the Netherlands.

In response to Russia’s military aggression against Ukraine, restrictive measures have been in place since 2014 following Russia’s actions destabilising the situation in Ukraine, including a ban on certain dealings with Russia (Council Regulation 833/2014 of 31 July 2014). As of 1 August 2024, within the framework of the enhanced supervision regime, the Netherlands is now enforcing the prohibitions arising from the sanctions against Russia. As a result the scope of existing enhanced supervision practices has been broadened, and an exemption must be obtained from the Ministry of Education, Culture and Science. The Territorial Integrity (Ukraine) Sanctions Order 2014 sets out how the sanctions are implemented in the Netherlands.

Since 1 August 2024, new exemption applications for research or study in one of the fields on the list of academic disciplines below have to be reviewed against the ban on providing technical assistance to Russia.

Individuals who enrolled in a course of study or started a research project in the relevant fields before 1 August 2024 do not have to apply for a retroactive exemption.

In determining whether to grant an exemption the Ministry of Education, Culture and Science will examine applications in the light of three sanction regimes. There are two different procedures:

Iran Sanctions Order 2012
After reviewing your application, the Ministry will send the knowledge institution in question an advisory opinion. It is then the institution’s responsibility to comply with the regulation and take the necessary steps to ensure that its terms are not violated.
North Korea Sanctions Order 2017 and Territorial Integrity (Ukraine) Sanctions Order 2014
After reviewing your application, the Ministry will send its decision to you directly.

Fields of study and projects that fall under the exemption requirement

Below is the list of fields of study by university or educational institution covered by the North Korea Sanctions Order 2017 and the EU Iran Sanctions Regulation. The list, which defines the fields in question as precisely as possible, is regularly updated.

The exemption requirement applies to the following specialisations and research groups of the Faculty of Aerospace Engineering:

Experimental and theoretical research in hypersonic aerodynamics;
Re-entry technology;
Control systems for guidance navigation;
Launching and payload structures.

The following specialisations and research groups of the Faculty of Applied Sciences:

Physics of nuclear reactors;
Specialised knowledge about the design and operation of the reactor hall of the HOR research reactor.

The following specialisations and research groups of the Faculty of Mechanical, Maritime and Materials Engineering:

Microturbine technology;
Use of materials at extreme high temperatures.

The following specialisations and research groups of the Faculty of Electrical Engineering, Mathematics and Computer Science:

Radar-based missile guidance.
Student projects that involve studying rocket and missile technology, including DARE – Stratos and SAPIENCE.

The exemption requirement applies to the following specialisations and teaching and research groups at the Faculty of Engineering Technology:

Non-linear Solid Mechanics;
Precision Engineering;
Applied Mechanics & Data Analysis;
Dynamics Based Maintenance.

The following student projects involving the study of rocket technology:

RISE (Rocketry Innovations & Space Engineering);
Rocket Project AzimUT of Space Society Twente.

Who is required to apply for an exemption?

This exemption requirement applies in particular to MSc students, PhD candidates and research staff who wish to:

enrol in a degree programme or conduct research in one of the above areas of education or research; or
take part in one of the student projects mentioned above.

Requirement also applies to certain practical activities

Anyone in a position to receive certain specialised knowledge must apply for an exemption. This may also be necessary in the case of practical activities, for example in a reactor setting or as part of certain extracurricular activities.

Applying for an exemption

Complete the application form truthfully and in full.

Include the following documents (provide a translation if the document is not in English or Dutch);

A copy of a valid passport or identity card (not a driving licence). Make a copy of your passport or identity card with your photo and citizen service number (BSN) (or similar identification number) blocked out. You can do this by covering the photo and number when scanning or photocopying the document;
Documentation showing how your studies, research or extracurricular activity will be funded;
A copy of your BSc and MSc certificates;
A copy of your list of grades for your BSc and MSc studies;
A copy of your residence permit (if you have already been granted one for reasons other than this application);
An invitation from the Dutch knowledge institution in question, an official job offer or a document expressing the intention to offer you a job;
Scientific publications (in PDF form, not a link).

Submitting your application

The completed questionnaire and all related documents should be sent to the Ministry’s Knowledge Embargo Desk at OCW-loket_kennisembargo@minocw.nl.

There are privacy risks associated with email communication. If this is a concern, you can send your application to the following postal address instead:

Ministry of Education, Culture and Science
Knowledge Embargo Desk
Postbus 16375
2500 BJ Den Haag
Netherlands

Timeframe for decisions

The Ministry of Education, Culture and Science may take up to 8 weeks to decide on your application. This period may be extended if it is not feasible to reach a decision within this timeframe. You will be informed in a timely manner if this is the case. It is important to ensure that your application is complete and truthful and includes all necessary documents. If that is not the case, the 8-week processing period will be paused, and you will be given the opportunity to supply the missing information. If you still fail to provide a complete application, your application will not be processed.

Further investigation

On the basis of your application the Ministry of Education, Culture and Science may decide that further investigation is necessary. This may involve an interview at the Dutch embassy in your country of residence or at the Ministry in The Hague.

Data processing

Your personal data will be handled in accordance with the privacy statement of the Ministry of Education, Culture and Science.

Exemption applications and visas/residence permits

If you need a visa or residence permit to live in the Netherlands, you must first obtain an exemption from the knowledge embargo before:

the Minister of Foreign Affairs can issue a decision on an application for a short-stay visa (which allows the holder to stay in the Netherlands for up to 3 months);
the Immigration and Naturalisation Service (IND) can issue a decision on an application for a residence permit (which allows the holder to stay in the Netherlands for longer than 3 months).

Objecting to a decision or advisory opinion

If you disagree with the decision or advisory opinion on your application, you can lodge an objection.

North Korea Sanctions Order 2017 and Territorial Integrity (Ukraine) Sanctions Order 2014
The review against the North Korea Sanctions Order 2017 and the Territorial Integrity (Ukraine) Sanctions Order 2014 will result in a decision. If you wish, you can lodge an objection to the decision within 6 weeks with the Education Executive Agency (DUO). The objection procedure will be explained in the decision you receive.
EU Iran Sanctions Regulation
The review relating to the EU Iran Sanctions Regulation will result in an advisory opinion, which will be forwarded to the relevant knowledge institution. If necessary, the knowledge institution will take measures to avoid violating the terms of the regulation. If you object to these measures, you can voice your objections to the institution. Contact the institution for more information.

Lodging a complaint about a government body

You have the right to submit a complaint about the conduct of a government body. If the complaint is about the advisory opinion, it will be assessed only in light of the ‘due care criterion’. In other words, did the government body in question act lawfully and provide a good reason for why it acted as it did? It is not possible to dispute the substance of the advisory opinion.

If you have any questions about the complaints procedure, you can contact the Knowledge Embargo Desk of the Ministry of Education, Culture and Science:

By email: OCW-loket_kennisembargo@minocw.nl
By letter:
Ministry of Education, Culture and Science
Knowledge Embargo Desk
Postbus 16375
2500 BJ Den Haag.

You are not obliged to provide a telephone number, but if you do, it will be easier for the Ministry to ask for further information or clear up any uncertain points.

What technology courses require an exemption from the knowledge embargo, and how can I apply for an exemption?

Sanctions

UN and EU sanctions against North Korea

EU Sanctions Regulation against Iran

EU sanctions against Russia

Simultaneous review (North Korea, Iran and EU sanctions against Russia)

Fields of study and projects that fall under the exemption requirement

Delft University of Technology

University of Twente

University of Groningen

Eindhoven University of Technology

Radboud University Nijmegen

Inholland University of Applied Sciences