The Wolf Amendment is not a permanent statute — it is an appropriations rider that Congress re-enacts, in substantially the same language, in NASA’s annual funding bill. It bars NASA (and, in current versions, the Office of Science and Technology Policy and the National Space Council) from spending appropriated funds on any bilateral activity with China or a Chinese-owned company, unless a narrow certification process is followed. For a principal investigator or research administrator deciding whether a planned collaboration is even proposable, the amendment functions as a scope-and-waiver judgment call, not a simple yes/no lookup — this guide walks through how to make that call correctly.
Quick-reference: does the Wolf Amendment apply to your collaboration?
| Question | If yes |
|---|---|
| Is the activity funded, in whole or part, with NASA appropriated funds (grant, cooperative agreement, contract, or in-kind NASA facility/personnel support)? | Wolf Amendment is in scope. If no NASA funds or NASA facilities are involved at any point, it does not apply — check whether another agency’s China restriction applies instead (see comparison table below). |
| Does the activity involve China, the People’s Republic of China government, or any Chinese-owned company as a bilateral counterpart? | Restricted unless certified under subsection (c) or the activity was specifically authorized by a later law. |
| Is the activity purely multilateral (e.g., an international consortium, an open scientific conference, or a body like the International Astronautical Federation) with no bilateral NASA-China channel? | Generally outside the amendment’s core prohibition, which targets bilateral policy, program, order, or contract activity — but document the multilateral structure carefully, since NASA’s own legal review is what ultimately decides this, not a self-certification. |
| Does it involve hosting an official Chinese visitor at a NASA facility, or at a facility used by NASA? | Separately restricted under subsection (b), regardless of whether the visit itself is “bilateral” in the programmatic sense. |
| Is a certification already on file covering this specific activity, submitted at least 30 days before the activity to the House and Senate Appropriations Committees and the FBI? | The restriction does not apply to that specific, already-certified activity. |
What the law actually says
The restriction originated as Section 1340 of the Department of Defense and Full-Year Continuing Appropriations Act, 2011 (Public Law 112-10), and has been carried forward — with the certification exception added in later years — in every subsequent Commerce, Justice, Science (CJS) appropriations act that funds NASA. The most recent full-year enactment, Section 526 of Division B of the Consolidated Appropriations Act, 2024 (Public Law 118-42), reads in operative part:
“(a) None of the funds made available by this Act may be used for the National Aeronautics and Space Administration (NASA), the Office of Science and Technology Policy (OSTP), or the National Space Council (NSC) to develop, design, plan, promulgate, implement, or execute a bilateral policy, program, order, or contract of any kind to participate, collaborate, or coordinate bilaterally in any way with China or any Chinese-owned company unless such activities are specifically authorized by a law enacted after the date of enactment of this Act.
(b) None of the funds made available by this Act may be used to effectuate the hosting of official Chinese visitors at facilities belonging to or utilized by NASA.
(c) The limitations described in subsections (a) and (b) shall not apply to activities which NASA, OSTP, or NSC, after consultation with the Federal Bureau of Investigation, have certified — (1) pose no risk of resulting in the transfer of technology, data, or other information with national security or economic security implications to China or a Chinese-owned company; and (2) will not involve knowing interactions with officials who have been determined by the United States to have direct involvement with violations of human rights.
(d) Any certification made under subsection (c) shall be submitted to the Committees on Appropriations of the House of Representatives and the Senate, and the Federal Bureau of Investigation, no later than 30 days prior to the activity in question and shall include a description of the purpose of the activity, its agenda, its major participants, and its location and timing.”
Because the provision is a funding rider rather than freestanding law, it technically expires with each appropriations act and must be re-enacted to remain in force. In practice it has been renewed every year since FY2011, including years funded by continuing resolution, where a full-year CR (such as the Full-Year Continuing Appropriations and Extensions Act, 2025, Public Law 119-4) generally continues the prior year’s appropriations conditions by reference rather than restating them line by line. Institutions should not assume a gap year — verify the current fiscal year’s enacted CJS appropriations act or governing CR before relying on prior-year certification language. Last verified against the Public Law 118-42 text on govinfo.gov: 2026-08-16.
Who the restriction actually binds
Read literally, Section 526 restricts how NASA, OSTP, and NSC may spend appropriated funds — it is an internal constraint on the federal agency, not a direct regulatory obligation imposed on a university or a principal investigator the way, say, an export-control regulation is. In practice this distinction matters less than it sounds, because it means:
- A university cannot “get a waiver” from the Wolf Amendment itself — only NASA, OSTP, or NSC can make the subsection (c) certification, and only for activities those agencies control or fund.
- A PI proposing NASA-funded work with a Chinese co-investigator, Chinese-owned company, or Chinese state entity needs to raise the question with their sponsored-programs or export-control office before the proposal is submitted, not after an award is made — NASA program officers are themselves bound by the restriction and will generally flag or decline bilateral China elements at the proposal stage rather than fund them and certify later.
- The restriction attaches to the activity, not to the individual — a researcher of Chinese nationality or origin working at a US institution is not restricted by this provision; the amendment targets bilateral engagement with China or Chinese-owned entities as counterparts, not the nationality of individual researchers. (Separate, unrelated federal policy areas — foreign talent program disclosure, NSPM-33 research-security disclosure requirements — govern individual affiliation disclosure and should not be conflated with the Wolf Amendment’s institutional bilateral-activity restriction.)
Practical scenarios researchers actually ask about
| Scenario | Likely treatment | Why |
|---|---|---|
| NASA-funded PI wants to co-author a paper with a researcher at a Chinese university, no data or funds exchanged, no formal agreement | Lower risk, but not automatically clear — check with your institution’s export-control/research-security office | Informal scholarly exchange without a “policy, program, order, or contract” structure sits closer to the multilateral/academic-exchange line, but the amendment’s language is broad (“participate, collaborate, or coordinate bilaterally in any way”), and NASA’s own guidance has historically been applied conservatively |
| NASA grant proposal includes a subaward or formal collaboration agreement naming a Chinese-owned company or PRC state research institute | Restricted; requires NASA-level certification before it can proceed | This is exactly the “bilateral policy, program, order, or contract” fact pattern the provision was written to reach |
| Multilateral scientific meeting or working group (e.g., under COSPAR or IAF) happens to include Chinese scientists among many nationalities | Generally outside the core restriction | No bilateral NASA-China channel; NASA participation is one of many nationalities in a multilateral forum, not a bilateral arrangement |
| Chinese national student or postdoc, unaffiliated with a Chinese government or state-owned entity, working in a NASA-funded US lab | Not restricted by the Wolf Amendment itself | The restriction targets bilateral activity with China/Chinese-owned entities, not individual nationality; separate research-security disclosure rules (NSPM-33, agency-specific foreign-affiliation disclosure) may still apply and should be checked independently |
| NASA wants to host a delegation of Chinese government science officials at a NASA center | Restricted under subsection (b) specifically | Hosting official Chinese visitors at NASA facilities is barred separately from the general bilateral-activity restriction and requires its own certification |
These scenarios are illustrative patterns drawn directly from the statutory text and NASA’s public description of the restriction — they are not a substitute for a case-specific determination by your institution’s export-control, research-security, or sponsored-programs office, and not every edge case has settled precedent.
The certification and waiver process
Subsection (c) is often loosely called a “waiver,” but it is more precisely a certification pathway that only NASA, OSTP, or NSC can invoke — an outside institution cannot self-certify or apply for one directly:
- NASA (or OSTP/NSC) determines an activity it wants to fund or conduct would otherwise fall under the restriction.
- NASA consults the FBI on the specific activity.
- NASA certifies that the activity (1) poses no risk of transferring technology, data, or other information with national security or economic security implications to China or a Chinese-owned company, and (2) will not involve knowing interactions with officials determined to have direct involvement with human rights violations.
- NASA submits the certification to the House and Senate Appropriations Committees and the FBI at least 30 days before the activity, describing its purpose, agenda, major participants, location, and timing.
For a university or research institution, the practical implication is: if a NASA-funded collaboration touches China, the earliest possible conversation with your sponsored-programs office and NASA program officer is the only route to finding out whether NASA is willing to pursue certification — this is not a process an institution can trigger unilaterally, and it is not fast (the 30-day notice requirement alone means it cannot be arranged at short notice before a planned visit or joint activity).
How this differs from other US-China research restrictions
Researchers frequently conflate the Wolf Amendment with several adjacent but legally distinct restrictions. They can overlap on the same project, so ruling one out does not clear the others:
| Restriction | What it actually governs | Applies regardless of NASA funding? |
|---|---|---|
| Wolf Amendment (NASA/OSTP/NSC appropriations rider) | NASA’s own bilateral engagement with China or Chinese-owned companies | No — specific to NASA (and OSTP/NSC) appropriated funds and facilities |
| Export Administration Regulations (EAR) / International Traffic in Arms Regulations (ITAR) | Controlled technology, software, and technical data transfers, including “deemed exports” to foreign nationals in a US lab, to any restricted destination — not China-specific | Yes — applies to any federally or privately funded research handling controlled technology, independent of funding source |
| NSPM-33 research-security requirements | Disclosure of all research support and foreign affiliations by federally funded researchers, plus institutional research-security program requirements | Applies to researchers funded by any federal agency implementing NSPM-33, not just NASA |
| Agency-specific foreign talent program restrictions (e.g., NSF, DOE, DOD malign foreign talent program bans) | Bar on participation in specified foreign talent recruitment programs as a condition of that agency’s award | Tied to the specific funding agency’s award terms, not NASA’s appropriations rider |
See CASRAI’s guides on ITAR and the US Munitions List, export control (EAR/ITAR) and international research collaboration, and the Research Security dictionary term for how these adjacent frameworks work in more detail.
Frequently asked questions
Is the Wolf Amendment a law, an executive order, or a NASA policy?
It is a congressional appropriations rider — a funding restriction attached to NASA’s annual budget legislation, most recently the Commerce, Justice, Science title of the applicable appropriations act. It is not an executive order and not a NASA-originated policy, though NASA implements it internally through its own bilateral-engagement review procedures.
Does the Wolf Amendment ban all contact between NASA and Chinese scientists?
No. It specifically restricts NASA’s use of appropriated funds for bilateral policy, program, order, or contract activity with China or a Chinese-owned company, and separately bars using funds to host official Chinese visitors at NASA facilities. Multilateral scientific engagement, individual scholarly contact without a NASA-funded bilateral structure, and activity outside NASA/OSTP/NSC funding are not automatically covered — but the language is broad (“in any way”), and institutions should treat close cases as requiring review rather than assuming exclusion.
Can a university get a Wolf Amendment waiver for a NASA-funded project?
Not directly. Only NASA, OSTP, or the National Space Council can make the subsection (c) certification, after consulting the FBI, and only for activities those agencies fund or conduct. A university’s role is to raise the question early with its NASA program officer and sponsored-programs office, since the institution cannot certify on NASA’s behalf or petition for a waiver independently.
Does the Wolf Amendment apply to non-NASA federal funding, like NSF or NIH grants?
No — Section 526 (and its predecessor Section 1340) applies specifically to NASA, the Office of Science and Technology Policy, and the National Space Council. Other agencies have their own, separately enacted restrictions on China-related collaboration (foreign talent program bans, agency-specific certification requirements) that are not the Wolf Amendment, even though the practical effect for a researcher can look similar.
What happens if a NASA-funded collaboration with China proceeds without certification?
The statute restricts NASA’s, OSTP’s, and NSC’s use of appropriated funds — the compliance exposure runs primarily to the funding agency and, by extension, to the funded institution’s continued eligibility and standing with NASA, not to a standalone criminal penalty provision within the amendment itself. In practice, NASA program officers screen for this at the proposal and award-management stage specifically to avoid funding an activity the agency itself is barred from supporting; institutions that raise a potential China-bilateral element only after an award is active should expect NASA to require it be resolved (certified, restructured, or removed) before funds can be used for that element.
Where to go next
If your collaboration involves controlled technology or technical data rather than a general bilateral policy/program question, start with CASRAI’s export control (EAR/ITAR) and international research collaboration guide. If it involves federal research-security disclosure obligations rather than NASA funding specifically, see the Research Security and Research Security Officer dictionary terms, and the NASA Research Security Training (GIC 26-02) term for NASA’s own internal training requirement. For institutional handling of foreign-entity relationships more broadly, see Confucius Institute Closures and Rebranding. For the broader compliance landscape this sits inside, see the Research Integrity & Compliance pillar.
