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Export controls on biological and chemical materials being sent out of the country

 

The shipment of biological and chemical materials outside of the U.S. must be compliant with U.S. export regulations including the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR) and the Office of Foreign Assets Control (OFAC). The exemption of fundamental university research from export licensing requirements does NOT extend to activities occurring outside of the U.S. or to the export of tangible objects from the U.S. regardless of the purpose of the export. Penalties for violation of the export control laws are significant and may include fines, imprisonment, and loss of future exporting privileges.


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.


Penn has several resources to assist in the determination of licensing requirements for the export of biological and chemical materials. Many of these may be accessed through the ORS website (http://www.upenn.edu/researchservices/exportcontrols.html ). Please contact your export control liaison for assistance in screening your transaction. Should a license be required, please contact expctrl@lists.upenn.edu

A request for a material transfer agreement (MTA) for research materials helps ensure that export control screening takes place prior to shipping or receiving of the materials.  Office of Research Services (“ORS”) evaluates each request for an MTA and performs screening as required.  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.  A request for a material transfer agreement may be made and submitted via the on-line system at:
                                                                                                    
https://medley.isc-seo.upenn.edu/researchInventory/jsp/fast2.do



Penn Resources

Decision Tree
Does your proposed activity require detailed review for compliance with Export Control Law?


Playbook for Global Engagement


University of Pennsylvania Export Compliance Manual

Export Control Quick Guides


Export Control Contacts

Information on H-1b and O-1 Visa Petitions and the I-129 Deemed Export Certification

Exporting Chemical and Biological Materials

Considerations for the Temporary Export of Research Equipment

End Use Certification

Technology Control Plan Template
Plan for the control of export controlled items and information

Cloud Computing and Export Controls

Travel to Cuba

External Resources

International Traffic in Arms Regulations (ITAR)

Office of Foreign Asset Control (OFAC)

Export Administration Regulations (EAR)

Council on Government Regulations information and analysis on Export Control

American Association of Universities information on Export control

Tips to protect laptops and electronic devices when travelling


Department of Commerce on-line Export Compliance Training

Consolidated Screening List

Article on Export Controls and Biological Research

Deemed Exports and Fundamental Research for Biological Items


   
 
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