International Trade Considerations
Sending or taking controlled information, technology, and items outside of the U.S. whether temporarily or permanently, is considered an export and may require an export license.
The list of items that may trigger a license requirement is long and includes biological material, electronics, genetic material, cameras, software, computers, design kits etc. Please review the Decision Tree for more details.
Note that an item's status as non-hazardous, commercial off-the-shelf, or research related is generally not relevant when assessing export licensing requirements for physical shipments.
The Export Control Office will help you:
- Determine the export classification
- Determine whether a license is required
- Check the receiving individuals and entities against restricted party lists
If required, the Export Control Office will apply for the license on Cornell's behalf
Other Shipping Considerations
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 Control Office will work together to determine if a license is required for the shipment of biologics or chemicals.
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.
Procurement Services will screen new vendors to ensure that you are not procuring items from a restricted entity.
In addition, Procurement Services reviews terms and conditions of vendor agreements for export and import 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 or import control requirements. Foreign nationals are generally permitted to use EAR controlled items on campus; however, access to controlled information, technology, source code and object code may require a license or other authorization.