Physical Exports (International Shipping & Hand-Carry)

Introduction

UMaine faculty, staff, and students frequently export items outside of the United States (U.S.) for research and scholarly activities and outreach. All exports, meaning any international transfers/shipments, including hand-carried1 items, made on behalf of UMaine must comply with export control laws and trade regulations, or risk substantial fines for the university and shipper/exporter, even if the export is temporary.

Exports may require export license(s) or documented use of a license exception, depending on the item, destination, recipient, and/or end use. Recipients of exports must be screened to ensure they are not a restricted party/entity. Exporting without obtaining the appropriate license or other government approval, or failing to file accurate export or shipping documentation, may result in the confiscation of the exported item(s), significant fines, and/or imprisonment. It is the responsibility of the shipper/exporter to ensure that a review of all physical exports is conducted by export compliance staff before the export occurs. Additionally, the shipper/exporter must comply with any requirements relayed by export compliance staff throughout the process, including keeping copies of relevant export documents (licenses or authorization letters) with the items to be exported.

Request an Export Review

To request an export review of your shipment/hand-carry, please review the following to determine what action to take:

  • If your only exports are a computer, tablet, phone, USB drive, memory stick, and/or external hard drive, please first review Export Compliance and Travel with Portable Electronic Devices to see if you qualify for a Temporary Export Certification.
  • For all other exports, prepare and submit a Request for Review of Physical Exports Form. Please submit the request as far in advance and with as much detail as possible to ensure that the Office of Research Compliance (ORC) has sufficient time and information to conduct a thorough review.
    • In addition to providing basic information about the export activity, the Request for Review of Physical Exports Form requires that you submit an itemized list of all items being exported using the Physical Export Inventory Template (Excel). Depending on your type and volume of exports, you may wish to complete this spreadsheet prior to beginning the request form.

Contact the export compliance team with questions at um.export@maine.edu.

Please note: The Office of Research Compliance’s review is solely focused on the export review of the shipment/hand-carry (i.e., need for license and/or documented use of a license exception to comply with U.S. Export Control Regulations). You will also need to work with your Department/College/Unit to ensure you follow all applicable shipping and travel policies and procedures.

Countries with Special Requirements

It is worth noting that some countries face export restrictions no matter the item.

Due to the export restrictions associated with the countries briefly summarized below, we must exercise greater due diligence regarding exports. Failure to comply with these requirements is considered a violation of export control regulations and may result in civil and criminal penalties. If you anticipate exporting to any of these countries, please reach out the export compliance team (um.export@maine.edu) as early as possible to initiate an export review.

For instance, comprehensively sanctioned countries face restrictions for all exports. Currently, comprehensively sanctioned countries include Belarus, Cuba, Iran, North Korea, Russia, Syria and the following regions of Ukraine: Crimea, Donetsk and Luhansk.

Some countries face restrictions due to potential “Military End Use.” For example, shipments (or hand-carried exports) of all items with a designated ECCN (Export Control Classification Number) that are exported to any party in Belarus, Burma, Cambodia, China (including Hong Kong), Nicaragua, Russia, or Venezuela require additional due diligence to ensure compliance with Military End Use and User controls.

Exports to China (including Hong Kong), Russia, and Venezuela require Electronic Export Information Filing (EEI), regardless of value. This could potentially include many items used to support academic activities, including but not limited to some laptops, software, and laboratory equipment which typically do not require EEI filing (unless the value exceeds $2,500).

Finally, some countries are subject to targeted sanctions which may carry limitations depending on the item(s) being exported. A full list of countries subject to sanctions can be found on OFAC’s Sanctions Programs and Country Information site (external link).

Again, if you anticipate exporting to any countries with special requirements, please contact the export compliance team at um.export@maine.edu as early as possible.

Additional Considerations

Exporting biological or hazardous materials requires extra due diligence, and often triggers licensing or permitting requirements. Shippers and travelers who plan to ship or hand-carry biological and/or hazardous materials outside the U.S. will need to coordinate with University of Maine System (UMS) Risk & Safety Management (sem@maine.edu) in addition to completing an export review with export compliance staff.

Additionally, in many cases, the export of biological material will also require a Material Transfer Agreement (MTA) to be executed prior to export. Be sure to leave sufficient time for coordination between all offices involved in the review, and for license and permitting processes in case they are needed!

Shippers and travelers should coordinate with UMS Risk Management to ensure the University has appropriate coverage for their specific activity and equipment. In some cases, additional action is required to ensure coverage is in place in case of loss, theft, or damage while abroad. For more information, see the UMS Risk & Safety Management website or Access the Risk Management Help Desk (both require @maine.edu log-in).

Documents required for exporting vary depending on the requirements of the receiving country and the item being received. Every country has unique import regulations that change frequently. As a result, exporters must ensure they have the appropriate documents to clear customs abroad before sending out their shipment. University exporters should ask their foreign importer what documents are required in their country, since errors in documentation can result in delays, nonpayment, and even seizure of goods.

For more information about international shipping documents, please see Common Export Documents from the International Trade Administration (external link).

Complex exports (and imports) will likely require working with a licensed customs broker outside the university. If utilized, associated costs are the shipper’s responsibility. Shippers are encouraged to coordinate with ORC early if a complex export is anticipated so that there is sufficient time (and funds) to work with an appropriate customs broker.

Electronic Export Information (EEI) Filing in the Automated Export System (AES) may be required for your export. EEI filing is required for shipments exceeding $2,500 and for any exports requiring an export license and for the situations described in the above section “Countries with Special Requirements.” (Note: Even though they are not considered “exports,” EEI filing is required for shipments to Puerto Rico or the U.S. Virgin Islands, unless the value of the shipment is under $2,500). Export compliance staff will determine if EEI filing is needed for your export, and if so, can complete EEI filing on your behalf; please contact um.export@maine.edu for assistance.

Export control regulations require that you, the shipper/exporter, maintain copies of all documents associated with the export for five years from the date of export. Be sure to request a copy of relevant documents from your shipping company or save/print them if using an online application.

  1. Note: All italicized links go to the ECR Glossary. ↩︎