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 Research Security & Trade Compliance (ORSTC) 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, and Syria.

Results: If yes, contact the ORSTC 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 List of Nuclear Facilities and Equipment) 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 ORSTC 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 ORSTC 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, 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, and Syria.).

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

Please note that while the ORSTC provides assistance for evaluating and/or filing export authorizations and related documents, the ORSTC 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:

• University of Pittsburgh - Environmental Health & Safety Department https://www.ehs.pitt.edu/
• University of Pittsburgh – Office of University Counsel http://ouc.pitt.edu/