International Shipments – Step-by-step Export Controls review

Step 1: Evaluate Prohibited End-Use

Review:

  • Do you have any reason to believe that the item, information or software to be shipped may support:
    • - the design, development, production, stockpiling or use of a nuclear explosive device, chemical or biological weapons, rockets/missiles, or space launch vehicles? or,
    • - a Chinese, Russian and/or Venezuelan military end-use? or,
    • - an illegal activity?
  • Does the material have any military, intelligence, space or nuclear applications?
  • Was the item, information or software developed under a sponsored agreement imposing publication restrictions or barring foreign national participation?
  • Did an external sponsor, vendor, collaborator or other third party provide the item, information or software to be shipped under a Non-Disclosure Agreement (NDA) or a Confidentiality Agreement?

Results: If yes, contact the Office of Trade Compliance (OTC) immediately and do not proceed with the export. If no, please continue the Export Controls review process.

Step 2: Evaluate Shipping Destinations - Embargoed and targeted countries

Review:

  • Are you exporting to an embargoed country or to an individual from an embargoed country? Comprehensively embargoed countries are: Crimea – Region of Ukraine, Cuba, Iran, North Korea, Sudan and Syria.

Results: If yes, contact the OTC immediately and do not proceed with the export. If no, please continue the Export Controls review process.

Step 3: Prepare Your Shipping label in ProShip

The Proship system is managed by University Express Mailing Service. All shipments must be processed through ProShip. https://expressshipping.fis.pitt.edu/pso/dashboards/view/208

Review:

  •  Is the item, information or software being shipped controlled by the ATF regulations, or the NRC regulations (i.e. appears in the Nuclear Equipment and Material List (NEML)) or the ITAR (i.e. appears in the U.S. Munitions List (USML) or has been specially designed for an item on the USML)?
  • Does the item, information or software being shipped appear in the EAR's Commerce Control List (CCL) and, therefore, is classified under an Export Controls Classification Number (ECCN)?

Results: If yes, contact the OTC immediately and do not proceed with the export.

*Note that items controlled under the ATF, NRC or ITAR required additional security measures: they must be secured from access by foreign nationals.

You do not need to contact the OTC and can proceed with the export only in the following cases:

  • - Item is classified as EAR99. This means that the item can be exported to most countries as No License Required (NRL), except to the Embargoed countries (Cuba, Iran, North Korea, Sudan and Syria.); or,
  • - Item is “Publicly available” or in the “Public Domain”, so is not subject to the Export Regulations and can be exported to most countries except to the Embargoed countries (Cuba, Iran, North Korea, Sudan and Syria.).

If you cannot obtain the classification of your item, please contact the OTC.

Export License: It takes approximately 6 to 8 weeks to obtain an Export License (official authorization) from the U.S. Government.

Documentations/records: Export documents must be kept for 5 years from their date of expiration.

Learn more: http://www.TradeCompliance.pitt.edu

Training: Pitt employees involved with international shipments are instructed to complete the CITI Export Controls modules: http://www.citi.pitt.edu/citi/

Get Help: TradeCompliance@pitt.edu 

Please note that while the OTC provides assistance for evaluating and/or filing export authorizations and related documents, the OTC is not in charge of managing actual shipments (including completing Customs and Shipping documentation). Also, other export and import requirements may apply prior to shipping your items.

We recommend to the Pitt Community to consult the following department and their websites:

IMPORTANT: This notice on International Shipments is provided for guidance purposes only and should not be considered legal advice. If you have any question, please contact the Office of Trade Compliances at the University of Pittsburgh.