UW Directories | Calendar | Map | MyUW
UW logo
Skip to Main
Office of Sponsored Programs (OSP)

Export Compliance: UW Shipping Guide

On this page …

UW Exports

Shipping items out of the U.S. from the University of Washington requires additional review and consideration. The University does not have a centralized shipping center for international or domestic shipments. Each department must determine the best practice and method related to the logistics in moving items, freight and cargo to the desired end-use location. If you are exporting an item that is export-controlled or if you need assistance in determining if your item is export controlled, please complete the Export Control Worksheet and send it to exports@uw.edu. Most exports from the United States do not require a license, and may be exported under the designation "No License Required" (NLR).

The primary responsibility for compliance with export regulations falls on the Principal Investigator or the responsible party for the transaction, also known as the "Principal Parties in Interest" (PPI). In addition to export controlled items, other conditions may be required in the packaging and shipment of dangerous goods. Please visit the Environment Health and Safety page for additional guidance and help on hazardous goods.

Questions to ask prior to any shipment:

  • Is my item "export-controlled" by the Export Administration Regulations (EAR) or the International Traffic in Arms Regulations (ITAR)?
  • If my item is "export-controlled" does it require an export license or the use of a license exception to ship to the end-use country?
  • Is the End-User on any restricted party lists (see export.gov for a consolidated screening list or contact OSP)?
  • Does the country of End-Use have sanctions or embargoes that prohibit or limit shipment (see treasury.gov)?
  • Are there any "red flags" about the shipment that make you question the legitimacy of the requested goods?

Restricted Party Screening

The Department of Commerce, State, and Treasury maintain lists of companies, entities and persons who may be prohibited or restricted. These lists have been consolidated into one list found on the export.gov website as a Consolidated Screening List. Prior to domestic and foreign shipments of goods, or transmission of export controlled software or technology, end-users should be screened against the Consolidated Screening List at a minimum. In addition to the screening an evaluation of the end-use and end-user should be done to ensure it does not result in an activity prohibited by any U.S. export regulations, or other restriction. In the event that an entity or person appears to match a party potentially involved in the transaction contact exports@uw.edu for assistance.

Freight Forwarders

Electronic Export Information (EEI) is required when merchandise is shipped from a United States Principal Party of Interest (USPPI), such as a unit at the University of Washington, to one consignee in a single country of destination, on a single conveyance, on the same day, valued over $2,500 per Schedule B, or when an export license is required. Exports of commodities where the value of the commodities under an individual Schedule B number valued at $2500 or less are exempt from filing. EEI's are filed via the Automated Export System (AES); maintained by the U.S. Census Bureau. All items shipped under an export license are required to submit an EEI regardless of value.

University employees shipping such items are encouraged to use an authorized agent. At this time, Expeditors and the Pasha Group are the University's authorized agents who provide EEI filings. The account representatives are Tanya Faddoul of Expeditors (tanya.faddoul@expeditors.com) and Fran Vollaro of the Pasha Group (fran_vollaro@pashanet.com).

If you need additional assistance in obtaining an export license, using a license exception or need help with required EEI information please contact exports@uw.edu.

Travel

Traveling internationally for the University of Washington on business does not exclude you from complying with export control regulations. Traveling with export-controlled items may require a license or the use of a license exception while you are out of the U.S. You are responsible in determining if your items are export-controlled and require the use of a license or license exception prior to traveling abroad. If you need assistance in determining if your item is export-controlled, please complete the Export Control Worksheet and send it to exports@uw.edu.

University of Washington employees may use license exceptions while traveling abroad. The most common exception being "TMP" (Temporary imports, exports and re-exports). This exception allows you to take the items and software abroad as a "Tools of Trade" as long as it is in "effective control" while abroad. You maintain effective control over an item when you either retain physical possession of the item, or secure the item in such an environment as a hotel safe, a bonded warehouse, or a locked or guarded exhibition facility. Tools of trade are exempt from filing requirements if the item is owned by the individual and intended for personal or business use and not for sale. Tools of trade under exception must be returned to the U.S. within one year from the date of export and must not be shipped under a bill of lading or air waybill. However, the use of TMP does not allow you to take items or software to Cuba, Iran, North Korea, Sudan, or Syria at this time. Please fill out the TMP Eligibility Certification form and maintain in your departmental file and on your person if you are making use of this export control license exception.

If you have any questions about the use of this or any other export control license exception, please contact OSP. For OSP to assist you, please review the CCL and have an idea of the potential Export Control Classification Number (ECCN) that applies to the material. Knowing the ECCN and the country(ies) you will be traveling to will enable OSP to assist you in determining if you are able to use a license exception. If your item is controlled by the ITAR contact OSP for license or license exemption requirements.

NOTE: When traveling with technical data that is export-controlled you incur a risk of inadvertently transferring controlled data to foreign persons and potentially committing an export violation. It is advised that only "clean" portable devices be taken outside the U.S. Contact OSP for alternative methods of access export-controlled technical data while abroad.

Red Flags

It is important to review export shipments for "Red Flags" which are possible indicators that an unlawful diversion may be happening. Shipping without a required license or to a prohibited destination or end-user must be avoided. If you feel like your shipment needs further review please contact OSP. Decide whether there are "red flags" of those involved in a project or those who are asking for export-controlled items, including software and technology. Take into account any abnormal circumstances in a transaction that indicate that the export may be destined for an inappropriate end-use, end-user, or destination. Review the denied party lists for all project members, end-users and others who may have access to the items.