Shipping Compliance

It is the responsibility of OHIO employees who are transferring items outside the United States, including hand-carrying items such as research equipment, materials, data, or biological materials, to be knowledgeable of and comply with export control laws and regulations. Any transfer of information, equipment, materials, or technology out of the U.S. by any method may be subject to export control restrictions and require an export license or be prohibited depending on the item, destination, recipient, and end-use. Even if an item is cleared through Customs, it may still require an export control license.

The simple act of sending a package to a foreign collaborator can result in a violation of export control regulations if a license is required. Also, shipping to countries subject to embargoes must first be cleared by the ECO and OGC. OHIO personnel who are responsible for shipping packages out of the country should obtain a list of contents before shipping in order to evaluate export restrictions and contact ECO with any questions. Shipping regulated items out of the U.S. without a license can result in sanctions against the university and significant individual fines.

Mislabeling the package or misrepresenting the classification of the item is illegal. Violations may result in civil penalties of up to $32,500 per violation, and deliberate violations may result in criminal prosecution of up to $500,000 and five (5) years in prison. Under-invoicing or undervaluing an exported item is also against the law. Reporting an incorrect export value on a Shippers Export Declaration is a violation of export regulations. Additional shipping guidance can be found on the ECO website. Any potential export control issues regarding shipping should be referred to the ECO.