Shipments/Transport – Questions to Answer

 

SHIPPING INTERNATIONALLY

College activities that involve the transfer of project information, equipment, materials, or technology out of the U.S. by whatever means will be subject to export controls and may require export license(s) depending on the item, destination, recipient, and end-use.

 

Export Guidance:  Shipments/Transport – Questions to Answer

Before you carry, ship or otherwise transport materials or equipment outside of the United States, you should determine if the commodity requires an export licenseIt can take several months to obtain a license. Guidance and assistance in making this determination and applying for a license are provided below.

It is important to clearly identify what you are exporting, to whom you are exporting it, and the purpose for which it will be used. You should answer the following questions:

1. What is it?  You should review the Commerce Department’s Commerce Control List and the Department of State’s Munitions List to determine whether the item(s) you intend to ship are subject to export restrictions. Always check with the manufacturer of any item(s) you intend to ship to determine the proper classification.

• The Commerce Control List is available at http://www.access.gpo.gov/bis/ear/ear_data.html
• The Munitions List is available at http://fas.org/spp/starwars/offdocs/itar/p121.htm
If the item you intend to ship appears on either list, you may need a license.

2. Where is it going?  The country of ultimate destination determines licensing requirements. Even if the item(s) you intend to ship are not on the CCL or USML, you may be prohibited from sending certain items to certain countries that are the subject of sanctions or embargoes, including the Western Balkans region, Burma, Côte D’Ivoire, Cuba, Democratic Republic of the Congo, Iran, Iraq, Former Liberian Regime of Charles Taylor, North Korea, Sudan, Syria and Zimbabwe. You can check the current lists of all sanctioned or embargoed countries at

If you are shipping to a sanctioned country, you may need a license.

3. Who will receive it? The ultimate recipient of your item cannot be on any of the lists of individuals and entities prohibited from receiving certain exports. The U.S. publishes several lists of individuals and entities that are prohibited from receiving certain types of goods, including the Denied Persons List, the Unverified List, the Specially Designated Nationals List, the Entity List and the Debarred Lists. Check each of these lists before proceeding with your purchase. Each list is available online in searchable form at http://www.bis.doc.gov/ComplianceAndEnforcement/ListsToCheck.htm.

4. What will they do with it? The ultimate end-use of your item cannot be subject to the EAR’s general end-use prohibitions. If the materials, equipment or technology are designed or adapted for a military application, or may be used in connection with or relate to the proliferation of weapons of mass destruction or terrorism it is unlikely that you will be able to ship or transport those materials abroad.

5. Red Flags. Check the Department of Commerce “Red Flag” list to identify possible violations of export control laws. The List is online: http://www.bis.doc.gov/enforcement/redflags.htmis available online.
You must secure license approval or verify license exception prior to shipment for all export-controlled items.

If any of these apply, contact OSP for guidance on verifying license exceptions and assistance for the submission of license applications, if required.