The University does not have a centralized shipping process for international or domestic shipments. Regardless, there are international shipping regulatory requirements depending on the item being shipped, its use abroad, and its ultimate destination.
To assist the UGA community with potential customs requirements and to prevent inadvertent violations of federal export control laws, please review the below information and contact the Office of Research Security and Export Control (ORSEC) for further assistance and to determine if an export license is required.
Individuals engaging in international shipments should contact the Office of Research Security and Export Control before shipment occurs. For items that are to be exported, either temporarily or permanently, an export classification and restricted party screening of the recipient should be completed by the Office of the Office of Research Security and Export Control.
Individuals may contact ORSEC in a number of ways:
- Informally, via email to email@example.com
- International travelers hand-carrying equipment or tools, or personal communication or electronic devices, may submit the “International Travel Export Control Review” form
- Export shipments of equipment or tools, related to international travel or not, may be submitted via the “International Shipping Export Control Review” form
Are you shipping or hand carrying an item to a comprehensively embargoed country?
Belarus, Cuba, Iran, North Korea, Russia, Syria, and Ukraine are currently subject to strict import and export license requirements. If you have a collaborator or want to send or receive items from one of these countries, contact the Office of Export Control.
Has a Restricted Party Screening been conducted?
The recipients of any international shipment must also undergo a restricted party screening. More information about restricted party screening is available here. The U.S. (and foreign governments) maintain a number of lists of sanctioned, debarred, or restricted persons or organizations. Please contact the Office of Export Control for assistance with screenings and to determine if an export license is required.
Has an export classification been assigned?
Export classification can be either an Export Control Classification Number (ECCN) or ITAR Category. These are US specific, determined based on technical listings in export regulations. Based on the export classification, an export license or license exception may be required based on the recipient entity, end user, or country destination. HS code or the Harmonized System Tariff code is the internationally standardized system of names and numbers for classifying traded products. It is a 6-10 digit number. The USHTS is the US version of the Tariff Code. Improper classification can lead to duties (taxes) or fines. In order to provide the most accurate classification, an adequate description or part number is required. The HS code and export classification can also be requested from the manufacturer. Is your item on the list of Export Controlled Items, Software, and Technology?
What is the valuation?
The World Trade Organization and customs in each country require accurate valuation of the goods. No country accepts a zero dollar value. The minimum value that can be declared is $1. If the item is not being sold, the invoice should indicate the value for Customs purposes only and “item not for sale, for research purposes only”.
Why is the valuation declaration important?
The value determines if there are special government filings required in the US prior to the export of the goods – Automated Export System (AES) Electronic Export Information (EEI). AES EEI must be filed for exports valued over $2500 (per HS code) or if an export license is required regardless of whether it is shipped or hand carried, with some exceptions. If an EEI is required, the AES ITN (proof of filing transaction number) must be listed on the airway bill. Declared invoice value is the basis for any applicable duty or taxes/fees that are due in the destination country. Customs knows what the typical value is for goods and a low value can be a red flag. If there are any import or export penalties, the penalties are assessed against the value of the goods.
- Valuation for Purchased goods: If the item was purchased, then the value to be declared should be equal to the PO price or quote.
- Valuation for In-house developed item, i.e. test equipment : The value should be the cost of goods + labor.
- Valuation for Prototypes provided free of charge: the supplier should provide the price of the item if it were to be sold.
Is an export license and/or EEI filing necessary?
US export regulations may require an export license or license exception based on the item (including technical data), shipping destination, value, or end user. EEI filing for shipments valued over $2500 or those that require an export license are required under the Foreign Trade Regulations. The Office of Export Control can review and advise on available export license exceptions.
Examples of when an EEI must be filed with shipments from the U.S. to foreign destinations include if any of the following applies:
- Shipment of a single item valued at more than $2,500. (Note: Shipments to Canada from the U.S. are exempt from this requirement.)
- A defense article controlled under the International Traffic in Arms Regulations (ITAR)
- A dual-use or commercial item that is enumerated in 9×515 or paragraph a. through x. of 9×515 or a “600 series” ECCN on the Commerce Control List, including exports to Canada.
- Exported under a BIS license
- Destined to a country in Country Group E1 (Iran, North Korea, Syria) or E2 (Cuba)
An EEI filing is required for shipments to China, Russia, and Venezuela for:
- Shipments of all ECCN items listed on the Commerce Control List (CCL), regardless of value or whether an export license is required. BIS regulations exclude EAR99 items of less than $2,500 in value.
Certain shipments of items under certain export licenses are exempted from an EEI filing. The Office of Export Control should be consulted for further details on these scenarios.
A pro forma invoice is required for all exports. You may also see this referred to as a commercial invoice. Although you may not be selling the item you are shipping, you will need a pro forma invoice if it is not personally owned. A pro forma invoice may be automatically generated if you are using an online expediter system such as FedEx or UPS. Further details about the pro form invoice are available from the International Trade Administration.
For researchers working with biological materials, there are a number of items that will require export licenses prior to being shipped outside the U.S. These include attenuated forms of bacteria, toxins, virus, and fungi or animals or material containing those items. Examples are available here.
There are many items that are not select agents, but do require export licenses as it falls under the controlled category for genetic elements and/or genetically modified organisms. Contact the Office of Export Control if you plan to ship biological materials internationally. Please note that an export license may take 6 weeks or longer to obtain.
Materials that require a Material Transfer Agreement should be coordinated with Innovation Gateway.
Dangerous Goods & Hazardous Materials shipments should be reviewed by Environmental Safety.
Biosafety should be consulted when shipping biohazardous materials.
Material being returned to a vendor must be reviewed via the Mail & Receiving Services “Material Return Slip and Shipping Permit” form.
The University has a contracted customs broker that may assist with freight forwarding and other logistics for larger items or ocean freight, for example. The broker primarily assists with imports.
Documents or promotional items are not necessarily required to be reviewed, unless they contain confidential or otherwise sensitive technologies or information.
Items to be shipped to Belarus, Cuba, Iran, North Korea, Russia, Syria, or Ukraine require oversight and potential U.S. government permission, regardless of the item to be shipped.
All shipping records including pro forma invoice, airway bill, export filings and associated communications are required to be maintained for a period of 5 years from the date of the export. Request a copy of relevant documents from your shipper or print them when using an online application. Your shipper (such as FedEx or UPS) will not keep copies of shipping records for you.
For every export, there is an import to the receiving country.
You are advised to contact your collaborator in order to comply with applicable import requirements to the destination country. Import requirements vary greatly by country, and your item(s) may be stopped by customs officials in the importing country if the proper paperwork is not in place.
U.S. Import Permits for Infectious or Toxic Agents or Wildlife
Certain items may require an import permit from CDC, USDA APHIS, or US Fish and Wildlife Service. The Office of Export Control is willing to assist on these respective agency permits.