International Trade Considerations
Shipping
Sending or taking controlled information, technology, and items outside of the U.S. whether temporarily or permanently, is considered an export and may require a license of authorization.
All international shipments must be approved by the Export Control Office, prior to shipment. Please submit the Shipping Form to expedite approval.
Factors that must be considered include:
- What is being shipped
- Who it is being shipped to
- The location of the end-user and any intermediate consignees
The Export Control Office can help you:
- Determine the export classification
- Determine whether a license is required
- Check the receiving individuals and entities
Other Shipping Considerations
See also the License Requirements section of Export Controls: Regulations and Overview for information regarding the export classification and export control authorization should a license be required to export.
Mohawk Global Logistics
Cornell University has awarded a contract to Mohawk Global Logistics (MGL) for the following products and services:
- Customs activities
- Custom bonds
- Freight forwarding
- Related services
MGL performs designated customs activities, including custom bonds and freight forwarding AND holds Cornell's power of attorney for these activities.
Should you be the recipient of an import, it is possible that the importer will require a power of attorney be signed prior to providing import services. This is also held by MGL.
Hazardous Material Shipping
Hazardous Materials shipment requires training by Cornell’s Environmental Health & Safety Office. For more information, see the Hazardous Materials page on the Environment, Health and Safety (EHS) site.
The EHS Biosafety Officer, Shipping Manager, and the Export Controls Officer will work together to determine if a license is required for the shipment of biologics or chemicals.
Procurement
New vendors are screened against restricted and denied party lists using licensed software from eCustoms.
In addition, Procurement Services reviews terms and conditions of vendor agreements for export control language which could trigger a review and classification of equipment or materials being purchased. Procurement Services policy includes export control procedures which can be found in the Buying Manual, Section 617. They also include departmental instructions for U.S. Customs clearance procedures.
Items Purchased for Research
The equipment and materials purchased by the University to support research and educational activities may be subject to export control requirements. Foreign nationals are generally permitted to use EAR controlled items on campus; however, access to controlled technology may require a license or other authorization. ITAR controlled items are not permitted on campus unless you have received prior approval from the Export Control Office.
All End User/End Use Statements and similar certifications must be approved and signed by the Export Control Associate or the Export Control and Compliance Officer
Record Retention
Under U.S. Export Control Regulations, and U.S. Import Regulations, records must be retained for five years after the completion of the activity and made available to the regulating authority upon request. Records that must be retained include all memoranda, notes, correspondence (including email), financial records, shipping documentation, as well as any other information related to the export activities. Additionally, when a license exception (EAR) or license exemption (ITAR) is used, or if a record is requested from a regulatory authority, additional records documenting the applicability of the exception/exemption may be required and, in some cases, there may be additional reporting requirements.
Records must be maintained by the individual or Unit engaging in the activity. Records shall be retained or disposed of in accordance with University Policy 4.7, Retention of University Records.