International shipping is subject to export and import controls, duties, taxes, and the regulations of the 196 countries – each different from the others. Fines, payment of unnecessary taxes, confiscation, or incarceration can all result from non-compliance with these regulations.
Everything that crosses the U.S. border is an export:
- even if it's temporary
- even if it wasn't sold
- even if it will be used for research
- even if it is only being shipped for repairs
Prior to shipping anything out of the United States, remember that once a shipment is made, it's difficult to fix if there are problems. Before you ship internationally, it is important to know the following:
- What is being shipped - do export controls apply?
- Where is it going - are there restrictions, sanctions or embargoes on the destination?
- Who will receive it - are there any prohibitions on the end user?
- What will it be used for - are there any prohibitions on the end use?
Answers to these questions will indicate whether or not you need an export license to ship. If the answer is "no" to all of the above, you may be able to ship "NLR" (No License Required). In some situations, a license exception may be available. If a license is necessary, it will take time to process; please plan accordingly. The Department of the Treasury's Office of Foreign Asset Controls will be contacted and involved in any shipment destined for an embargoed country.
Shipments of items controlled under the ITAR or EAR should be clearly marked as controlled, with appropriate regulatory control cited. Any licensed export, as well as exports with a dollar value greater than $2,500 must be entered into the Department of Census Automated Export System (AES) prior to the export of the item or information.
Some items are hazardous, and need to be packaged and labeled appropriately. Contact Environmental Health & Safety for assistance if you are shipping biologicals, chemicals, batteries and fuel cells, radioactive materials, or any other hazardous materials. In addition to assisting with packaging, EH&S will review shipments for export controls.
Use eShipGlobal for international shipping
The University is the shipper of record, responsible for shipping correctly and getting the paperwork right. FedEx, UPS, DHL, and any freight forwarder may help or offer advice, and they record the shipment in the government's Automated Export System, but if there's a problem, it is the University's problem, not theirs. When an export controlled item is shipped, the documents, including licenses or license exceptions, must be retained in accordance with standard export control record-keeping regulations as they document an export control transfer.
Per UAM 4,760, the University requires the use of eShipGlobal, an online shipping management program, for all international shipments. Use of eShipGlobal will ensure that your shipment is reviewed for export control issues prior to shipment.
If you expect to receive a shipment from outside the U.S., remember that all incoming shipments are imports and are cleared by U.S. Customs with varying (and unpredictable) levels of scrutiny. Import duty may be due, based on the item's tariff code and its value. The shipment can be delayed or incur unexpected costs if the paperwork is incorrect or incomplete. Please note, import duties may be applied even to equipment being returned to the U.S. after being repaired if the shipping documentation is not prepared correctly.
If you are importing an item, material, software or technology that is controlled for export, contact Michele Dondanville to create a Technology Control Plan to protect against unauthorized access.