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Michigan State University Export Control & Trade Sanctions

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International Shipping 

The Office of Export Control and Trade Sanctions (ECTS) provides assistance to MSU’s research community with export compliance related to international shipments. MSU adheres to numerous Export Control Regulations, including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), the Office of Foreign Assets Control (OFAC) sanctions and embargoes, and regulations from the Department of Energy and Nuclear Regulatory Commission.  ECTS assists MSU personnel with export classifications of export-controlled technologies prior to shipping internationally. 

The Export Control Regulations may apply to physical shipments as well as items hand-carried during international travel, including items packed in luggage and data or software stored on a laptop. ECTS will evaluate international shipments to run export classifications, apply for necessary export licenses if needed, and coordinate with MSU University Procurement and Logistics (UPL) on shipments. MSU personnel are responsible for complying with export control laws and regulations while engaged in activities on behalf of the University.  It is important to notify ECTS as far as possible in advance of an international shipment so that ECTS has sufficient time to review and classify items being exported, prior to export.

Who do I contact for assistance with an international research shipment?  

Contact both MSU’s Office of University Procurement and Logistics Shipping Office (UPL) and MSU’s Office of Export Control and Trade Sanctions (ECTS) prior to an international shipment.  The two offices will coordinate on international shipping requirements, including the following:

  • ECTS will work MSU personnel to run export classifications and confirm whether items may be exported to the intended international location. If needed, ECTS will also assist with filing appropriate export license applications. ECTS will coordinate with UPL on the appropriate export classifications, but ECTS does not manage physical shipments or create shipping and customs documentation.

  • UPL will arrange the collection of packages and help MSU personnel select a shipping service. UPL will run Restricted Party Screening to ensure that MSU is not shipping to sanctioned individuals or entities. UPL will also help determine HTS codes for the item or material to be shipped and provide guidance for completing shipping and customs documentation. For certain destinations, UPL will verify the end-use and end-user and may request an End-Use Statement to be signed by the recipient.   UPL will coordinate with ECTS to confirm export classifications are complete prior to shipping.  

Who do I contact if I need to hand-carry items out of the U.S.?   

Contact MSU’s Office of Export Control and Trade Sanctions (ECTS) for a review of data, materials, equipment, or software that you would like to hand-carry out of the U.S. ECTS will work with you to determine the appropriate export classification and whether an export license is required prior to shipment.  ECTS has guidance on hand-carrying items on its International Travel webpage under the Tools of Trade License Exemption Guidance.  Please contact ECTS as early as possible in advance of your shipment so that ECTS has time to review and classify the items being exported.

What items need an export control license prior to being shipped internationally?

Whether a shipment needs an export license will depend on several factors: 1) the export classification of the data, materials, equipment, or software, 2) what country/region the shipment is going to, and 3) the recipient or ultimate end user of the shipment.  International shipments may require export licenses depending on the item, destination, end-use, and/or the end-user.  MSU’s Office of Export Control and Trade Sanctions (ECTS) will run export classifications and assist with any export licenses needed for your international shipment.

What if I am shipping biological or radioactive materials? 

MSU’s Office of Environmental Health & Safety  (EHS) provides guidance for radioactive materials packages for MSU personnel who request biological material shipments. EHS coordinates with University Procurement and Logistics (UPL) to determine the applicable shipping regulations. In general, UPL manages shipments of fixed biological materials, chemicals, or dry ice, and if you are planning to ship pathogenic organisms, please contact EHS’s biosafety team at ehs@msu.edu   

When do I need to use a Data Use Agreement or a Material Transfer Agreement?  

It is always best practice to use a Data Use Agreement (DUA) or Material Transfer Agreement (MTA) as this will notify the appropriate offices at MSU of the international transfer.  MSU Technologies assists with DUA’s and MTA’s for the exchange of data and tangible research materials.  MTA’s and DUA’s should be fully executed prior to exporting any data or materials out of the U.S. Contact cdamta@msu.edu to begin the MTA process or visit the MTA, CDA & DUA - MSU Innovation Center site for additional information.  MSU Technologies coordinates with ECTS for review of these agreements and export classifications as needed. 

What are the repercussions of not complying with U.S. Export Control Regulations?    

Violations of U.S. Export Control Regulations can result in customs delays, seizure of goods, and lost time and opportunities. Monetary penalties for violating the Export Control Regulations can be severe, both for an individual and the University.  Please contact MSU’s Office of Export Control and Trade Sanctions (ECTS) before shipping or hand-carrying items internationally or sharing data or software outside of the U.S.   

Who can assist with international shipments?  

  • Environmental Health & Safety provides guidance for shipping pathogenic biological materials and radioactive shipments. For more information, please contact EHS at ehs@msu.edu.   
  • Export Control & Trade Sanctions (ECTS) provides export classifications for international research shipments for MSU’s research community. For more information, please contact ECTS at export@msu.edu.   
  • MSU Innovation Center assists with contracts, such as Data Use Agreements and Material Transfer Agreements. For more information, please contact the MSU Innovation Center CDA/MTA/DUA team at cdamta@msu.edu.  
  • University Procurement and Logistics Shipping Office (UPL) assists researchers in meeting compliance and hazardous materials shipping requirements, manages package pickups, and provides guidance to researchers on selecting appropriate carriers. For more information, please contact UPL at upl.dl.mailservices@msu.edu.   

 

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Export Control & Trade Sanctions

4000 Collins Rd.
Lansing, MI 48910
export@msu.edu
517-432-4499

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