Import and Export


Export controls

U.S. federal export control regulations broadly regulate the export of certain items (including physical commodities, technology/information and software) from the U.S. to other destinations. Export controls can apply to a wide range of research activities, regardless of the source of funding. The regulations can impact certain activities related to conducting research abroad. Export control violations are severe and carry heavy penalties including imprisonment and fines. Emory's Export Control Office manages the university's export control program and can assist you with navigating the any potential export control concerns that may affect your research. Contact the Export Control team with any questions at exportcontrol@emory.edu.

The good news about export controls is that much of the research activity conducted at universities in the U.S. falls within the scope of the fundamental research exclusion. In addition, in many cases, an exclusion or license exception can be obtained without applying for a license.

What is an export?

For the purposes of the export control regulations, “export” has a broader meaning than its everyday use. Exports occur when:

  • Anything physically departs the U.S. regardless of how it is transmitted (e.g., shipments, emails, texts, phone conversations, hand-carrying overseas)
  • Technology or software source code is shared with a foreign national either abroad, or in the U.S. (this is known as a deemed export - see more below)
  • Performing certain types of services

Learn more about Export Controls

Comprehensively sanctioned and embargoed countries

Activities conducted in or involving nationals of sanctioned/embargoed countries are severely limited and may require specific authorization from relevant regulatory agencies. Before engaging in any activity with Cuba, Iran, Syria, North Korea, or the Crimea region of Ukraine, contact the Export Control Office at exportcontrol@emory.edu for guidance. An export license from the U.S. government may be required and this can take several weeks, even months before it is issued, so it is important that you contact the Export Control Office as soon as possible.

Shipping and hand-carrying items abroad

Export Control Regulations apply to items taken outside the U.S., regardless of the shipping method. Depending on factors such as the item, destination and intended use, some shipments may require specific authorization from federal agencies in order to be lawful.

In some cases, Electronic Export Information (EEI) filing may be required when shipping or hand-carrying items outside the U.S. In many cases where an item will be exported to a destination permanently (e.g., laptops for study counterparts that will not return to the US) and the item is valued at more than $2,500, EEI filing is required. In cases where an item is being shipped/permanently exported to China (including Hong Kong), Russia, or Venezuela, EEI filing may be required regardless of the item’s value. When traveling to Cuba, both permanently exported items and items that will return to the U.S. (e.g., laptop, cell phone, camera) require EEI filing. If an export license has been obtained from the authorities, an EEI filing is always required.

Global Services can assist departments with EEI filing, and in cases of shipping with a vendor such as Fedex, the vendor can complete the EEI filing on your or Emory’s behalf. Please note, however, a vendor may still require you to provide key information about the item. If you have any questions about EEI filings and whether your items will require it, please contact the Export Control Office at exportcontrol@emory.edu.

Temporary exports

When taking or shipping university equipment which will be brought back to the U.S. within a year, you can rely on the Temporary Imports, Exports, Reexports, and Transfer (In-Country) Exception or the TMP. The TMP license exception allows you to take Emory property provided the item is (a) kept under the traveler’s effective control and, (b) brought back to the U.S. within a year of the departure date. Please note that the TMP exception does not apply to items or technologies controlled under the International Traffic in Arms Regulations (ITAR). In addition, some equipment such as global positioning systems, thermal imaging cameras, and inertial measurement systems are highly restricted and may require a license even when hand-carried. Review the TMP checklist found here to determine applicability of the TMP exception.

Permanent exports

Before shipping or hand-carrying equipment, technology, or other materials abroad, that will not be brought back to the U.S. within 12 months or that is intended as a permanent export from the U.S., please contact the Export Control Office at exportcontrol@emory.edu to help you determine if an export license is required.

Transactions or Activities Involving a Restricted or Prohibited Party

The federal agencies responsible for administration of export control regulations maintain lists of restricted or prohibited parties. In the event that a transaction or activity involves a party (company, entity, or person) appearing in one of the lists, additional due diligence must be conducted before proceeding with the activity or transaction. Depending on the list, there may be a strict export prohibition, specific license requirements, or presence of a “red flag.” Restricted Party Screening (RPS) helps in determining if a party to a transaction appears in any of the lists. Before transacting or doing business with any foreign national or entity, contact Global Services to conduct Restricted Party Screening.

Deemed exports

A deemed export occurs when technology, technical data, or software source code is released or transferred to a foreign person in the U.S. The release or transfer is deemed to be an export to the foreign person’s home country. Your department may be required to address deemed export considerations as part of international student and scholar immigration requirements. Please contact the Export Control Office at exportcontrol@emory.edu if you have any questions. 

Shipping and import considerations

If you will be shipping materials to your research site or back to the U.S., you may need assistance clearing customs. Emory has a relationship with Fedex Trade Networks. Please reach out to Global Services to connect with the appropriate customs brokerage contact.  

To ensure biological materials are shipped safely and effectively, Emory recommends working with the Environmental Health and Safety Office (EHSO) and employing a trusted shipping agent. Emory has relationships with World Courier and Marken. Global Services or EHSO can support you in connecting with these shippers. 

Shipping infectious agents, biological materials, and/or dry ice packaging is heavily regulated. If you will be shipping such items for your international program, EHSO offers training to guide you through the process. Training is typically available in a classroom setting once every other month (course code 240220 in the EHSO course catalogue).  

Contact Robin Ruthenborg in EHSO for additional information.

Learn more about shipping biologics and other potentially hazardous materials

Traveler customs restrictions

Be aware of the customs restrictions for travelers to foreign countries, as well as what is allowed for travelers returning to the United States.

Some international locations are eligible for preferential duty-free entry for products when imported into the United States. 

Learn more about the U.S. Generalized System of Preferences (GSP) program

Contacts

Rose Ndegwa

Export Control Office, Office of Research Administration

Robin Ruthenborg

Environmental Health & Safety Office