International Shipping

International shipments are subject to numerous export and import regulations. You cannot ship anything to a restricted party without prior federal authorization. The U.S. government maintains lists of restricted individuals and organizations, which are frequently updated. Shipping to a restricted party without federal approval is a violation of federal law and University policy. In addition, many items (i.e., materials, substances, equipment, technical data, software) require federal government authorization (e.g., export control license) before shipping.

International shipments are also subject to Foreign Trade Regulations (FTR). These regulations require filing of Electronic Export Information (EEI) in the Automated Export System (AES), when the value of the commodity classified under each individual Schedule B number is over $2,500, or if there exists a mandatory filing requirement. Shipments of items on the Commerce Control List to China, Russia, or Venezuela, require EEI filing regardless of value, unless an export exemption applies. There are instances when the EEI is not required, for example, for shipments from the U.S. to Canada regardless of value. Contact the ECIC office for assistance in determining whether your shipment requires EEI filing.

Reach out to the ECIC office for a review and license determination for international shipments when they involve:

High Risk Countries - These countries change over time but are currently:
- Heavily OFAC Sanctioned Countries: Belarus, Cuba, Iran, North Korea, Russia, Syria, and certain regions of Ukraine (Crimea, Donetsk, Luhansk)
- Military End-Use (MEU) or Special Control Countries: Belarus, Burma, Cambodia, China (including Hong Kong), Iraq , Nicaragua, Russia, Venezuela.
Biological, chemical, or hazardous materials and accompanying technical data, regardless of country.
- We recommend that you start by contacting NU’s Research Safety office. Hazardous material shipping is regulated by the Department of Transportation and there are a range of government agency requirements. Research Safety coordinates with the Export Controls team to see if an export control license is needed. Make sure you have a licensing determination in writing from the Export Controls team before shipping internationally.
A critical technology area, regardless of country. Example: quantum computing, integrated circuits, artificial intelligence capabilities, additive manufacturing, semiconductor materials, semiconductor manufacturing equipment, chip design software. List of critical technology areas.
Defense articles or military applications. Northwestern is not registered with the State Department DDTC, to handle/store/work with ITAR projects.

Shipping Frequently Asked Questions

What can you do to avoid an export violation? Contact the Export Controls & International Compliance (ECIC) team to conduct Restricted Party Screenings and a licensing determination for international shipments. This is critical for shipments of controlled items and in the scenarios described above, including to high-risk countries.

What is a licensing determination? To determine if a license is required, the export control review is a two-step process, we: (1) conduct restricted party screenings to make sure the intended recipient is not on a restricted list; and (2) work with you to classify your item and identify any applicable Export Control Classification Numbers (ECCNs) or US Munition List (USML) categories, to determine if we need an export license. Export regulations also have end use and end user restrictions that will be checked during the review. The ECIC will request the following initial information to conduct a review:

Which group/department intends to send this shipment?
Who are you sending the item(s) to? Name of recipient, employer/affiliation, and shipping address.
What are you sending? Including all details (scientific name, lay person description, CAS number, amount or size, if it's pathogenic or hazardous)
What is the purpose of the shipment (what will they be doing with the items)?
Where was the sample obtained from? If the material was purchased, provide vendor information and a link to the material on the vendor's website.
Is there any known or expected military end use?
What is your target date for the shipment?
Will the item(s) come back to the U.S.? If yes, when?
What is the estimated value of the shipment?
Is this project federally funded? If so, who is the sponsor?

What items need an export control license? It depends on the item, the intended recipient, and country. The Export Controls team can assist you in making a licensing determination and apply for the license. Email the Export Controls team in advance of your shipment. Doing so may save your shipment from being returned or destroyed.

The equipment and technologies covered by the regulations are extensive, from software, computers, cameras, centrifuges, autoclaves, accelerators, radiation detectors, etc., to various chemicals, biological agents, and toxins. The list of items that may be subject to some form of regulation is approximately 50 pages long. Each item has detailed specifications (e.g., not all cameras are subject to export controls), and, notably, only technologies that are not publicly available are subject to the controls. However, special rules apply to even publicly available encryption software. The export control regulations classify each item for country-specific restrictions. For example, some items require a license to share with specific countries; others may be shipped only to Canada without a license, while other items are allowable to most but not all countries.

What if I am shipping biologics or chemicals? Start by contacting Research Safety once you have determined what needs to be shipped. Hazardous material (e.g., biologicals, chemicals, and radiological materials) shipping is regulated by the Department of Transportation. There are a range of government agency requirements. Research Safety coordinates with the Export Controls team to see if an export control license is needed. Make sure you have a licensing determination in writing from the Export Controls team before shipping internationally.

If I have already shipped to an individual, university, or vendor before, do I need to request another Restricted Party Screening? Yes, the restricted party lists change quickly and frequently, so it is critical to request a screening for each new shipment.

What happens if I ship an item to a Restricted Party or country without the proper license? University personnel who engage in international shipping are responsible for complying with U.S. export control laws and regulations. Not following regulations may result in lost items or criminal or civil penalties. However, if we voluntarily report the potential violation, the government may consider the disclosure as a mitigating factor when making penalty decisions. For that reason, you should always contact the Export Controls team for assistance if you think there may be an export control violation.

Who can provide assistance with customs and shipping forms? The ECIC office does not manage the customs and shipping portions of international shipments. For questions on shipping chemical and biological samples please contact Research Safety. For general inquiries, Procurement and Payment Services offers a Shipping Guide and Customs Information, as well as information on Northwestern's Preferred Customs Vendor. See also Who can assist me? section below for contact information and additional details and resources.

Who can assist with EEI filing? If EEI filing is required for your international shipment, please reach out to your courier, as they may offer this service. Alternatively, you can contact a customs broker for assistance. (See e.g. FedEx EEI information, Northwestern's Preferred Customs Vendor).

What is a Material Transfer Agreement?
An MTA is a written contract that governs the transfer of research material between organizations. You may also need a Material Transfer Agreement to share, receive and protect materials. All MTAs should be submitted to Sponsored Research for review and signature.

Learn more about MTAs or email the MTA team.

Who can assist me?

Export Controls & International Compliance team conducts Restricted Party Screenings and helps determine if you need an export control license.
Procurement and Payment Services offers general shipping guidance and links to Northwestern’s preferred Customs Broker for more complex shipments.
Research Safety provides assistance and training to help members of the University community comply with shipping regulations for biological, chemical or radiological materials.