NASA has long-standing restrictions in its awards related to China.

“In accordance with Public Law 113-235, Division B, Title V, Section 532, NASA is prohibited from funding any work that involves the bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, at the prime recipient level or at any subrecipient level, whether funded or performed under a no-exchange-of funds basis. Accordingly, proposals shall not include bilateral participation, collaboration, or coordination with China or any Chinese-owned company or entity, whether funded or performed under a no-exchange-of-funds basis. Proposals involving bilateral participation, collaboration or coordination in any way with China or any Chinese-owned company, whether funded or performed under a no-exchange-of-funds basis, will be ineligible for award.”

“China or Chinese-owned company” means the People’s Republic of China (PRC), any company owned by the PRC or any company incorporated under the laws of the PRC. Chinese universities and other similar institutions are considered to be incorporated under the laws of the PRC and, therefore, the funding restrictions apply to grants and cooperative agreements that include bilateral participation, collaboration or coordination with Chinese universities.

For more information, please review the ROSES FAQs provided by NASA. For questions or analysis of whether an activity falls under this restriction, please reach out to our export controls and sanctions professionals in Research Security and Compliance

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