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Import Compliance Guidance

The ECIC team does not review import compliance for international inbound shipments. Recipients at Northwestern are responsible for obtaining all required permits and ensuring that the shipper provides an accurate description of the materials to the carrier.

However, ECIC will manually run restricted party screenings on the sender for international inbound shipments that are shipped to Northwestern University as the recipient.

Reach out to Procurement & Payment Services with questions.

All items

  1. Request restricted party screenings for imports of any items (materials, samples, specimens, chemicals) imported from high-risk countries. Reach out to the ECIC team at least 3 weeks in advance.
  2. Make sure you provide complete and accurate information to the carrier and on all customs documents. This is a crucial step to remain compliant and avoid issues. There have been recent enforcement actions related to imports of biological materials into the U.S. that underline the importance of complete and accurate descriptions of imported materials and appropriate documentation accompanying certain imports, including imports of biological samples and live animals.
  3. Depending on the complexity of your import, consider reaching out to a customs broker to help you complete and submit customs paperwork. Make sure the broker has experience with the type of item you intend to import. Reach out to NU Procurement and Payment Services for additional customs broker information and check out their Shipping Guide.
  4. Consider if you need to put a material transfer agreement (MTA) in place. Review Sponsored Research MTA guidance to identify if an MTA is needed for your material transfer.
  5. Northwestern and federal sponsor disclosures:
    1. If the PI receives federal funding, they must disclose support received for research—including in-kind support—to their federal sponsors. If you have questions on what or how to report, contact your department research administrator for guidance and check Northwestern's Pending & Other Support Guidance.
    2. Northwestern also requires disclosure in different scenarios relevant to international research collaborations. See COI Guidance for Researchers and contact the COI office if you have questions

Biologics

  1. Determine and maintain documentation on whether the biologics you are receiving contain, or code for, any toxin, or any gene or genes specific to any controlled virus, bacterium, or fungus, or is hazardous to human, animal, or plant health, or could endow or enhance pathogenicity.
  2. There are various agencies (example: USDA/APHIS, Fish & Wildlife, CBP, CDC) and regulations that oversee imports of biological and hazardous materials. We recommend conducting a thorough search of all applicable requirements and in doubt reach out to each agency with questions. Helpful information and links:
  1. Make sure you provide complete and accurate information to the carrier and on all customs documents. This is a crucial step to remain compliant and avoid issues. There have been recent enforcement actions related to imports of biological materials into the U.S. that underline the importance of complete and accurate descriptions of imported materials and appropriate documentation accompanying certain imports, including imports of biological samples and live animals.
  2. If you’re importing a live animal, check with Northwestern IACUC for guidance.

Equipment

The Florence Agreement provides the duty-free entry of articles imported for educational or scientific purposes at any nonprofit institution, whether public or private. Duty-free applications are subject to review by US Customs and are not guaranteed to be approved. Additional conditions must be met. Reach out to NU Procurement and Logistics for additional information and assistance.