Exports & International Sanctions
With homeland security a major priority over the past several years, the federal government has substantially increased its scrutiny of university compliance with federal regulations controlling the export of goods, technologies and information. In response, the University of Pittsburgh recently reviewed its own policies and practices with regard to the export regulations and is in the process of developing new procedures and educational training to aid in compliance.
Exports of Purchased Goods and Services
There are several export regulations with which the University must comply including the Export Administration Regulations (EARs), the International Traffic in Arms Regulations (ITARs) and others. These regulations restrict the export of certain goods, technologies and information, and various federal departments maintain lists of items that are restricted from export, as well as specific countries that may be banned from receiving such goods from the United States.
If you are purchasing products that will be shipped to locations outside of the U.S., or are contracting for services to be performed at locations outside of the U.S., the following procedure applies:
1. Department identifies international component.
2. The department will select a supplier or service provider and complete a University of Pittsburgh requisition in the PantherExpress System.
3. Notify PantherExpress Customer Service via a Purchasing Requisition Inquiry. This inquiry should state that you have goods to be delivered or services to be provided at a location outside of the United States. Your inquiry should provide as much information as possible about the supplier or potential supplier such as name, address, tax identification number, and the type of goods and services that you are considering for purchase.
4. A PantherExpress representative will contact you within 24 hours to provide assistance.
5. After speaking to the representative, forward all documentation to Purchasing Services, 3309 Cathedral of Learning.
6. Purchasing Services will coordinate directly with the supplier to determine its ability to ship the goods overseas directly. If the supplier does not have the ability to comply with export regulations, Purchasing Services will coordinate with the University’s customs broker to determine whether the University may ship the goods outside the United States and identify any licenses that may be necessary.
In accordance with United States Export Control laws, two departments (the University’s Office of Export Controls Services and the PantherExpress team, respectively) need to review the Export Controls Classification on the following types of goods and services if they are purchased by the following schools or departments: 1. Natural Sciences Division of the Dietrich School of Arts and Sciences; 2. the Swanson School of Engineering; and 3. the School of Information Sciences.
For schools and departments not listed above, obtaining an Export Controls Classification for goods having a single value greater than $5,000 will be optional. However, if the recipient of the items knows that the items will be exported out of the U.S. now or in the future, the Office of Export Controls Services continues to recommend that the classification of the item be obtained from the supplier.
Note: University departments should follow the procedures implemented for shipment when an item is being sent by the University to a location outside of the U.S. For assistance, please contact the Office of Export Controls Services.
Export Controls Classification Submission
In order to comply with U.S. export regulations, the following areas: the Natural Sciences Division of the Dietrich School of Arts and Sciences; the Swanson School of Engineering; and the School of Information Sciences must obtain an Export Controls Classification from the supplier (for any applicable good e.g. an individual item that is over $5000) and include it, along with other supporting documentation, with the requisition submission. The supplier may provide the Export Controls Classification information in any of the following formats:
- on a quote;
- on a separate document
- in the body of an email message; or
- on the University’s Product Classification Certification form.
For services, Office of Export Controls Services review is needed only in the instance where an item is being sent by the University (school or division mentioned above) to a supplier outside of the U.S. In this case, the University will need to determine, prior to transferring the item to a foreign party/destination, if an export license is required or not (i.e. will need to determine the item’s classification and the destination country). Please contact the Office of Export Controls Services team (EChelp@pitt.edu) prior to exporting any item out of the U.S.
The supplier may inform the University that an item is classified under one of several possible classifications or U.S. government agencies -
- a U.S. Munitions List category, thus subject to the ITAR;
- the Department of Energy – Nuclear Regulatory Commission;
- the Department of Homeland Security - Bureau of Alcohol, Tobacco, Firearms and Explosives; or
- an Export Control Classification Number (ECCN), thus subject to the EAR.
Affected University schools and divisions (listed above) may find that most of the items purchased by the University will be classified by the EAR and will have a five character ECCN (for example, 3A001). ECCNs are used to identify dual-use items for export control purposes. An ECCN categorizes items based on the nature of the product, for example, type of commodity, software, or technology and its respective technical parameters. Suppliers may state that the ECCN is EAR99. EAR99 items can be exported to all countries, except embargoed countries (Cuba, Iran, North Korea, Sudan and Syria) and will require minimal review by the Office of Export Controls Services team and Purchasing Services.
In addition to EARs and ITARs, the U.S. Treasury Department Office of Foreign Assets Control (OFAC) maintains its own list of foreign countries, specially designated nationals and other blocked persons against which the United States has issued economic or trade sanctions. See the OFAC website for further details.
Purchasing Services regularly compares all existing University suppliers and service providers to the OFAC lists to ensure the University’s compliance. Purchasing from University-wide contracted suppliers is the fastest way to order a product or service.
A number of corporations, foundations and other grant-making organizations are beginning to require, as part of the grant terms, a certification from the University stating that it does not conduct business with any country or person on the OFAC list.
Purchasing Services, along with the Office of General Counsel, will assist you in completing all requests for certification of the University’s compliance with international economic and trade sanctions.
If you have received a request to provide certification of compliance with OFAC restrictions, please notify us via a Purchasing Requisition Inquiry.