Export Controls apply to any shipment or hand-carry of items or technology outside of the U.S and transfer of technology to a foreign national within the U.S. All members of the Harvard Medical School community are required to comply with Export Control and Specially Designated Nationals regulations and should seek guidance if sending (or carrying) Harvard materials, services, technology or data owned outside the United States. Prior to the shipment or hand-carry of any items or technology outside of the U.S. or transfer of technology to a foreign national within the U.S., an export control review must be conducted by the HMS Export Control Administrator.
During an export control review, the HMS Export Control Administrator will need key pieces or information from you about the item or technology to determine the Export Control Classification Number (ECCN) of the items or technology, screen the parties and countries who will receive the item or technology, and review the usage of the items or technology by the recipient. These pieces of information are necessary to determine if an export license or license exception is required for the export. Please note that while in most cases an export control review can be completed quickly, if an Export Control license is required, the application must be submitted through the US Department of Commerce or the US Office of Foreign Assets Control and can take several months (12 weeks or longer) to receive a decision. Faculty and researchers should plan research efforts with these time frames in mind.
Questions pertaining to the export control review process or export control documentation (commercial invoices, Shipper’s Letter of Instruction (SLI), Electronic Export Information (EEI)) may be directed to the HMS Export Control Administrator: firstname.lastname@example.org.
EH&S also assists laboratory researchers to safely package shipments and transportation of dangerous goods including chemicals, radioactive materials, and biological materials, by ground, air, or sea in order to comply with the U.S. Department of Transportation (DOT) regulations, International Airline Transportation Association (IATA) guidelines and/or Maritime law. Transporting certain materials may also require import/export permits or other documentation from federal agencies including, US Border Protection and Customs, FDA, USDA/APHIS, Fish and Wildlife, and CDC.
Please consult with EH&S prior to shipping any materials, to a domestic or foreign destination, from Harvard Medical School. EH&S can be reached at: Phone: (617) 496-3797; EHS_ResearchTransport@harvard.edu
The PI should also be aware of and approve the release of any materials from his or her lab. Researchers are not allowed to take research materials or data from Harvard without permission. Researchers are encouraged to discuss with their PIs, on a regular basis, what materials they think they will need to take with them upon their departure.