Upcoming Changes to Shipping Requirements for China, Russia, and Venezuela
Guidance and Resources
It is important to keep in mind that the exemption of fundamental university research from export licensing requirement does not extend to activities occurring outside of the United States or to the export of tangible objects from the United States, regardless of the purpose of the export.
When shipping internationally, it is important to check that the individuals or entities to which materials are being shipped are eligible to receive those materials, i.e. they do not appear on “specially designated national” or “banned parties” lists and are not in embargoed locations. Additionally, materials that could be used for the manufacture of biological or chemical weapons, chemicals that are used as propellants and high explosive materials may require specific licenses for export. Shipment of these controlled materials should be planned well in advance, as it may take several weeks to several months to obtain the license.
When shipping internationally:
Utilize Material Transfer Agreements in Penn’s Research Inventory System
- A request for a material transfer agreement (MTA) for research materials helps ensure that review for both export compliance and environmental health and radiation safety takes place prior to shipping or receiving of the materials. An MTA also helps protect the Principal Investigator and Penn by clarifying the rights and obligations of the parties with respect to publication, patenting and other issues. Clarity with respect to rights and obligations can help head off any disagreements that may arise in the absence of a clearly expressed statement regarding what the parties intended.
Use eShip@Penn for all Penn-related shipments (FedEx, UPS, DHL)
- All international shipments processed via eShip undergo screening to ensure that the recipient and destination are not prohibited.
Use Penn’s authorized customs brokers/freight forwarders (large, heavy, high-value items and complex shipping destinations)
Please note that there are additional shipping-related regulations and/or agencies that come into play when shipping biologic, chemical, or radioactive materials either internationally or within the United States. For more information on these types of shipments, as well as training opportunities, see Penn’s Office of Environmental Health & Radiation Safety (EHRS).