Shipments

International Shipping Documentation

 

  • International Shipment Review Survey REDCap survey
    • Submit this survey for each instance of an export (international shipment) occurring at least 10 business days prior to your international shipment.
      • The International Shipment Review survey is required for ALL international shipments, regardless of whether or not the contents are export-controlled, who they are going to, or where they are going.
      • This survey can also be used to document and request review of domestic (U.S.-based) shipments of confirmed export-controlled commodities.
    • This survey is required to be completed and submitted by a supervisor, manager, admin, or investigator of the VUMC department responsible for initiating and dispatching the shipment and never directly by the recipient or an intermediary.
    • Certain shipments may require an End-User End-Use Statement ("EUEUS"), please review the EUEUS page to determine if this additional documentation is necessary for your shipment.
    • For record retention, all documentation related to the shipment should be kept for ten (10) years past the last date of recorded activity.
       
  • Work with the Export Compliance office to determine:

Foreign Shipments

Foreign exports require additional time in advance to prepare all necessary requirements and documentation before being able to ship/transfer. While some items or information (technology/technical data) may be considered export-controlled under EAR or ITAR, others are not controlled. All items to be exported should be reviewed for:

  1. potential export to a sanctioned country,
  2. proper export control classification (ECCN or USML Category),
  3. intended end-user of concern, or
  4. for support of a prohibited end-use.

You may be required to obtain a license from the federal government for your export and in some situations, a license may not be granted. The Export Compliance Review Flow Chart may be used as a supplementary tool in the analysis of your shipment.

Utilization of the International Shipment Review and End-Use End-User Statement (EUEUS) forms above will assist the Export Compliance office in ensuring all international shipments are reviewed prior to shipping.

  • Compliance in this matter will ensure such shipments are neither controlled for export nor are being exported to an entity or individual (intermediary or end-user) on the Denied Party List (DPL).

Contact the Export Compliance office to determine if the item is controlled for export, and to ensure the item is not being exported to an entity or individual on the Denied Party List (DPL).

  • the Export Compliance office will provide a copy of the search records to you upon request.
  • Keep these results with the project file for ten (10) years past the last date of activity on the project.

US Shipments

The U.S. Bureau of Industry and Security (BIS) also requires that export-controlled items shipped to an entity (company, organization, university, contact, etc.) in the U.S. be reviewed prior to shipment to ensure they are not being exported to an entity on the Denied Party List (DPL).

For U.S. and foreign shipments, contact the the Export Compliance office to conduct restricted party screening (RPS). REDCap survey

  • the Export Compliance office will provide a copy of the search records to you upon request.
  • Keep these results with the project file for ten (10) years past the last date of activity on the project.

Shipping chemicals, biological agents, toxins, etc.?

Use the Restricted Biological Agents (Viruses, Bacteria, Toxins, or Fungi) PDF and the Restricted Chemicals PDF lists as general guidance to determine whether or not the materials in question have export control restrictions.

Contact both the Export Compliance office and Environmental Health & Safety in OCRS immediately. (Even if the shipment is domestic.)

Destination Control Statement ("DCS")

According to 15 CFR §758.6, the exporter must incorporate the following statement on the shipping documentation and/or commercial invoice whenever items on the Commerce Control List are shipped (i.e., exported in tangible form), unless the item(s) are designated under the export classification number or “ECCN” as EAR99:

  • “These items are controlled by the U.S. Government and authorized for export only to the country of ultimate destination for use by the ultimate consignee or end-user(s) herein identified. They may not be resold, transferred, or otherwise disposed of, to any other country or to any person other than the authorized ultimate consignee or end-user(s), either in their original form or after being incorporated into other items, without first obtaining approval from the U.S. government or as otherwise authorized by U.S. law and regulations.”

For more information about the DCS and its requirements, please visit the following site: https://bit.ly/2MqQ56W

Best Practices

BEFORE each shipment, it is important to consider:

  • What is the item or information? (Is it export-controlled?)
  • Where is it going?
  • Who will receive it?
  • What will be the end-use? (How will it be used?)

It is important to consider all of the above before each shipment as federal regulations change frequently.

Know Your Partner(s)

The Bureau of Industry and Security (BIS) provides very helpful guidance when considering who to do business/collaborate with:

  1. Know your customer/collaborator.
  2. Look for Red Flags that can help you recognize potentially illegal transactions.
  3. Request a Restricted Party Screening from the export compliance office.
  4. Report illegal transactions or any encouragement by internal or external parties to violate international laws immediately.

Review Supplement 3 to 15 CFR 732 for guidance from the U.S. Department of Commerce.

FedEx: VUMC-Approved International Carrier

United States Postal Service (USPS) - Mail

Customs Broker & Imports

If your transaction relates to imports or requires the expertise of a customs broker, VUMC has an approved vendor: V. Alexander & Co.