Shipper Self Assessment Review Procedure

Additional Information Why Does Correct Classification Matter?

How to Conduct a Shipper Self-Assessment for Export Compliance

Step #1: Restricted Party Screening (RPS)

Conduct a RPS using eCustoms Visual Compliance (VC). Is the vendor on a U.S. export restriction or denial list?
• Yes, STOP - contact the Export Compliance Office.
• No, continue to Step #2.

The parties to the export include, but are not limited to, the: exporter, recipient institution/entity, shipping company, freight forwarder, consolidator, end‐user and any transport company.

Step #2: Prohibited End Use

To the best of your knowledge, will the item or information be used for a prohibited end‐use?
• Yes, STOP - contact the Export Control Officer.
• No, continue to Step #3.

Exports in support of activities related to the following are (generally) prohibited without a license:

o Nuclear Explosives, Power (reactors) or Propulsion
o Rocket/Missile, Space Launch Vehicles, or Unmanned Air Vehicles Activities
o Chemical and Biological Weapons
o Weapons of Mass Destruction
o Use on Foreign Vessels or Aircraft

Step #3: Embargoes and Trade Sanctions

Are you exporting to or for the benefit of someone in one of the comprehensively sanctioned countries?
• Yes, STOP - contact the Export Control Officer.
• No, continue to Step #4.

The following countries are currently subject to comprehensive sanctions: Cuba, Iran, North Korea, Sudan and Syria.

Step #4: Regulatory Jurisdiction

What is the regulatory jurisdiction of the item or information?
• If you can confidently determine the jurisdiction, continue to Step #5.
• If you are unsure, STOP – contact the Export Control Officer for assistance.

Different items or pieces of information in your shipment may be subject to different jurisdictions. Most common jurisdiction for University items or information:

o International Traffic in Arms Regulations (ITAR) – Directorate of Defense Trade Control Decision Tree Tools
o Export Administration Regulations (EAR) – Bureau of Industry and Security Decision Tree Tools
o Nuclear Controls – Nuclear Regulatory Commission or Department of Energy

Step #5: Export Control Status

What is the specific control status of each item or piece of information?
• If you can confidently determine the export control status, continue to Step #6.
• If you are unsure, STOP – contact the Export Control Officer for assistance.

For the jurisdictions listed above, status is:

o ITAR – U.S. Munitions List (USML) Category Number including applicable paragraph and subparagraph designations
o EAR – Commodity Classification List (CCL) Export Control Classification Number (ECCN)
o Nuclear Controls – specific controlling regulatory citation (10 CFR 110 or 810)

Step #6: License Determination

Is a license generally required to export the item or information to the country of destination?
• Yes, continue to Step #7.
• No, you may export the item or information without a license. Go to Step #8.
• If you are unsure, STOP – contact the Export Control Officer for assistance.

All items and information subject to the ITAR require an export license.

Step #7: License Exception/Exemption

Is there an applicable license exception, exemption, or general authorization to overcome the license requirement for all of the items and information in the shipment?
• Yes, you can export the item or information (all of them) without a license so long as you can comply with all stated requirements for the exception(s) or exemption(s).
• No, STOP - contact the Export Control Officer for assistance applying for an export license or other authorization.
• If you are unsure, STOP – contact the Export Control Officer for assistance.

Step #8: Census and Customs Filing

(A) For this shipment, are you required to file an Electronic Export Information (EEI) form, a.k.a. Shippers Export Declaration (SED), with AES?
• Yes, continue to 8B.
• No, no further action is required.
• If you are unsure, STOP – contact the Export Control Officer for assistance.

(B) Will the shipper or freight forwarder be filing the on the University’s behalf?
• Yes, complete the EEI/SED with the shipper or freight forwarder. Ask the shipper or freight forwarder to provide proof of AES filing.
• No, STOP - contact the Export Control Officer for assistance filing the AES paperwork (e.g., for hand‐carries and US mail shipments or when the shipping company does not have a limited power of attorney to file on behalf of the University).

In order for another party to file on behalf of the University, they have to be designated as our “agent”. This is commonly done through a Shippers Letter of Instruction (SLI) or a Limited Power of Attorney (LPA). University signatory authority is required to sign an SLI or LPA; since international shipping or freight forwarding is the procurement of a service, the appropriate contact is Cyril Rickson at Cyril.rickson@stonybrook.edu or 631-632-6290.

If you will be temporarily (less than one year) exporting an item ask the shipper or freight forwarder about using an ATA Carnet.
ATA Carnets ease the temporary importation of commercial samples, professional equipment, and goods for exhibitions and fairs. They are accepted in about 80 countries and facilitate international business by avoiding extensive customs procedures, eliminating payment of duties and value‐added taxes (minimum 20% in Europe, 27% in China), and replacing the purchase of temporary import bonds. TECRO/AIT Carnets are similar to ATA Carnets but are only used between the US and Taiwan and only apply to commercial samples and professional equipment.

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