Research involving non-EU countries

Conducting research outside the EU has become an increasingly common practice across all disciplines, and one that introduces a specific set of ethical considerations researchers must address proactively. Any research involving countries or communities with weaker regulatory frameworks, less institutional oversight, or significant socioeconomic disparities compared to the researchers’ home context carries an elevated risk of ethical imbalance. This is not simply a matter of legal compliance: it is a question of responsibility, fairness, and scientific integrity.

Two practices are particularly problematic in this context:

• Ethics dumping occurs when research that would not be permitted, or would be subject to much stricter controls within the EU, is deliberately or inadvertently carried out abroad. This can happen when researchers, sometimes without realising it, take advantage of less stringent local rules or weaker oversight mechanisms. The European Commission has explicitly identified ethics dumping as a concern under the Horizon Europe framework: activities funded under these programmes must meet EU ethical standards regardless of where they take place, and any activity prohibited across all EU Member States cannot receive EU funding.
• Helicopter research (also called « parachute science ») refers to a pattern where researchers from higher-income settings design and carry out studies in lower-income or marginalised communities with little or no involvement of local researchers, and with limited benefit flowing back to those communities. Examples include designing studies without consulting local needs, or collecting biological samples abroad for analysis and commercialisation entirely at home (Nature, 2022). This practice raises serious questions about power imbalances, intellectual property, benefit-sharing, and the long-term sustainability of research partnerships.

Key risks to consider

Before and during a project involving non-EU countries, researchers should reflect on whether their study involves any of the following:

• Vulnerable populations: communities with limited access to legal protection, health resources, or political voice, including people in conflict zones, refugees, or marginalised groups.
• Significant power or resource asymmetries: situations where participants, local researchers, or partner institutions have considerably less bargaining power than the research team.
• Use of biological, genetic, or cultural resources: collection of human biological material, plant or animal specimens, genetic sequence data, traditional knowledge, or cultural artefacts, all of which may be subject to national access and benefit-sharing regulations.
• Data protection gaps: contexts where local data protection standards fall below those required under the GDPR, which continues to apply to EU-based researchers regardless of where data is collected.
• Risk of stigmatisation or harm: research on topics such as sexual behaviour, political beliefs, or health status that could expose participants to discrimination, legal jeopardy, or social harm in their local context.
• Potential depletion of local resources: diverting local healthcare workers, laboratory staff, or institutional capacity away from existing services to support the research project, without adequate compensation or planning.
• Environmental and animal welfare standards: situations where local regulations offer weaker protections than those in the researchers’ home country.

The TRUST Code: a practical ethical compass

The TRUST Code (Global Code of Conduct for Research in Resource-Poor Settings) is a recognised practical framework for addressing the ethical challenges of cross-national research, developed under the EU Horizon 2020 programme and adopted by the European Commission as a reference document for Horizon Europe applicants. It is built around four core values:

• Fairness: Research should be locally relevant and co-designed with local partners. Local researchers and communities should be meaningfully involved at every stage, including in decisions around data ownership, intellectual property, and authorship. Where research draws on biological materials, traditional knowledge, or non-renewable resources, free and prior informed consent must be obtained, and formal agreements must govern any transfer of materials or knowledge.
• Respect: Researchers must explore cultural sensitivities in advance with local communities and partners. Local ethics review should be sought wherever possible, and host-country ethics committees must be treated as genuine oversight bodies, not as a formality.
• Care: Informed consent procedures must be adapted to local contexts to ensure genuine understanding. Research that would be prohibited or severely restricted in a high-income setting should not be carried out in a lower-income one simply because local rules are less developed. When exceptions are justified, this must be transparently documented using the « comply or explain » principle.
• Honesty: All collaborators must reach a shared and documented understanding of their respective roles and responsibilities. Language barriers or limited institutional capacity can never justify withholding or presenting information incompletely. Lower local data protection standards are not a licence to accept privacy risks that would not be tolerated at home.

What you should do

Before the project starts

• Conduct an ethics self-assessment and complete the Ethics Issues Table if applying for or implementing EU-funded research. Consult the EU Grants: How to complete your ethics self-assessment.
• Contact your local ethics committee early. Retroactive approval is not possible, and ethics review is a precondition for publication in many journals and for funding eligibility.
• Identify whether local ethics approval is required or available in the host country, and seek it wherever it exists.
• Check whether the Nagoya Protocol applies if your research involves genetic resources or associated traditional knowledge. The EU ABS Regulation (511/2014) governs due diligence obligations.
• Verify GDPR compliance even when collecting data outside the EU. Consult your institution’s Data Protection Officer.
• Involve local researchers and communities from the design stage. Co-develop research questions, methods, and benefit-sharing arrangements.

During and after the project

• Monitor ethical questions dynamically: ethics is not a one-time clearance. New issues can arise during fieldwork and must be addressed promptly.
• Ensure feedback reaches participants and communities in a form that is meaningful and comprehensible in their context.
• Document and honour benefit-sharing agreements, and review them as the research evolves.
• Apply the higher standard whenever local regulations offer weaker protections, whether in data privacy, animal welfare, environmental safety, or any other domain.

Institutional contacts

Each institution has its own ethics committee and procedures. If your project involves research in or with non-EU countries, contact your local ethics committee before the project begins.

• UCLouvain
• ULiège
• ULB
• UMons
• UNamur

Key references and further reading

• TRUST Code — Global Code of Conduct for Research in Resource-Poor Settings
• Horizon Europe Programme Guide — Ethics (Section 12)
• EU Grants: How to complete your ethics self-assessment
• European Code of Conduct for Research Integrity (ALLEA, 2023)
• EU Regulation on Access and Benefit Sharing — Nagoya Protocol implementation (511/2014)
• Mind the GAP — VLIR online training on research integrity (including ethics rules and regulations)
• VLIR- Guidelines for Researchers on Research Security, Dual Use and Misuse of Research