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 license and assist the University in securing the license, when required. It can take several months to obtain a license. Guidance and assistance in making this determination and applying for a license are provided below.
- Consult with the University’s customs broker to ensure that your shipment abroad meets other legal requirements, including customs and packaging requirements. Details about the University’s customs broker and their services are available at the Office of Sourcing & Procurement.
To determine the applicability of export licensing requirements, you should review the following steps. If, after this review, you have any questions, please contact Marie Hladikova, Export Control Director (617-353-6753; firstname.lastname@example.org).
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 (CCL) and the Department of State’s Munitions List (USML) 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.
If the item you intend to ship appears on either list, you may need a license.
2. Where is it going?
The country of the item(s) final destination determines the 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:
- Dept. of Treasury Sanctioned Countries
- Dept. of State Country Policies and Embargoes list
- Dept. of Commerce Lists to Check
If you are shipping to a sanctioned country, you may need a license.
3. Who will receive it?
The final recipient of your item(s) cannot be on any of the lists of individuals or entities prohibited from receiving certain exports. The United States 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 Export.gov.
If the intended recipient of your shipment appears on one of these lists, contact Marie Hladikova, Export Control Director.
4. What will they do with it?
The end-use of your item(s) 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.
If the end-use of your item(s) may be prohibited, contact Marie Hladikova, Export Control Director.
5. Red Flags
Check the Department of Commerce “Red Flag” list to identify possible violations of export control laws.
If any of these red flags apply, contact Marie Hladikova, Export Control Director.
Note regarding Materials Transfer Agreements (MTAs): The Office of Technology Development (OTD) generally processes requests to transfer research materials from Boston University to researchers, academic institutions, or other third-parties and uses standard forms and agreements to do so. If you intend to transfer research materials to a researcher, academic institution, or other third-party outside of the United States you must complete OTD’s Export of Materials Checklist before your request may be processed. If you think the materials you will be transferring may be subject to export controls, please inform OTD at the time of request.
You must also secure license approval or verify license exception prior to shipment for all export-controlled items. Contact Marie Hladikova, Export Control Director, (617-353-6753; email@example.com) for guidance on verifying license exceptions and assistance for the submission of license applications, if required.