All shipments leaving PSU with foreign destinations must be compliant with export control laws, and must be reported to the government when circumstances require the University to do so. All shipments leaving the country are exports, even if they are leaving the country temporarily, they are not intended to be sold, or are loaned to another entity. All exports should be reviewed prior to departure to ensure that its shipment would not violate US export controls. This includes shipments of items, software, biological samples, and any other tangible items. It should be noted that international transfers of most documents are not subject to export controls. In industry, ensuring export compliance in outgoing international shipments is a primary duty of logistics operations, however, academia has sometimes overlooked this important aspect of export controls, as the focus has historically been on export compliance in the conduct of research. Universities routinely ship items internationally, and are obligated to ensure compliance in international shipping activities. It should also be noted that shippers are also obligated to comply with the import and customs regulations of the destination country, which can be stringent.
Whether shipping by express service, postal service, or freight forwarder, the shipper of record is PSU. As the shipper of record, PSU is responsible for providing accurate details of the shipment to whatever party is transporting the goods. If shipping equipment or anything other than common consumer goods internationally, the shipper should know the export classification of the item. Only by knowing how the item is classified under US export regulations can shippers determine if a license is required for the shipment. On the paperwork that shipping companies frequently require shippers (the shipper being defined as the party who initiated the shipment, not the party who provides transportation) to complete, there will be fields that ask for the export classification of the goods (ECCN, Schedule B, HTS, USML category, or something similar). As the shipper of record, PSU is required to provide accurate information about the commodities exported. PSU exporters should contact the ECO in advance of the shipment to ensure that the correct classification is used for the shipment.
Any shipments of goods and items with a value over $2500, anything going to a comprehensively sanctioned country, or anything that is exporting under an export license, must be declared to the US government via the Automated Export System (AES). The declaration itself is known as the Electronic Export Information (EEI). The information collected via the EEI is used by the Census Bureau to compile trade statistics, and the information is also distributed to other federal agencies with a need to know (such as US Customs). It is a violation of the foreign trade regulations to provide inaccurate information on the EEI. Shipping companies usually can perform the declaration on behalf of the shipper for a fee, or the shipper can make the declaration themselves via their own AES account. The ECO controls the AES account for PSU and can make export declarations for PSU exporters.
It is absolutely critical to complete all export related paperwork accurately. Shippers are liable for what they put on export paperwork. Domestic export authorities and foreign customs can and will enforce compliance with the requirement to complete paperwork with absolute accuracy. Some foreign customs agencies will issue fines for things as trivial as typographical errors. Shippers should take care to not underestimate the value of the shipment, as this can be seen as an attempt to underpay import duties by foreign customs agencies. A best practice for exporters is to always favor accuracy over speed or cost.
An important service of the ECO is to assist the University community with reviewing planned exports for compliance issues, working with PSU exporters to overcome any compliance issues that may arise (including applying for export licenses), and assisting PSU exporters with the logistical aspects of their exports. It is recommended to contact the ECO as soon as a PSU party knows they will be making a shipment abroad. Early consultation with the ECO helps to avoid delays if it is determined that extra procedures, such as a license application, must be undertaken to ensure compliance.
Contact:
Research and Graduate Studies
1600 SW Fourth Ave.
Portland, Oregon 97201
Phone: 503-725-9944
Fax: 503-725-8170
Email: export@pdx.edu