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Procurement and Logistics

  • Do you ship documents or technical data?
  • Do you ship biological materials, plants, or chemicals?
  • Do you use refrigerants, like dry ice, in your shipments?
  • Do you order items through online merchants, like Amazon?
  • Are you relocating lab equipment and other materials to a new location?
  • Are you using Carnet's (Kar-nay) for temporary importing?

 

  • Are you relocating lab equipment or other items to another location?
  • Are you relocating lab equipment or other items to another location?

Shipping items can be an overwhelming feat for those who rarely or occasionally coordinate such activities.  However, when shipping internationally, coordinating these activities can be more than putting something in a box or envelope and calling for a pickup.  

When shipping internationally, the following questions should be considered:

  • What is being shipped?
    • Is the item considered hazardous? export controlled? import controlled? 
    • Are any special documents required, such as end-user statements or certificates of authenticity?
  • Where is the item being shipped to? 
    • Is the location an embargoed or restricted destination?
  • Whom is receiving the shipment?
    • Is the person / entity identified as a prohibited or restricted party on a government designated list?

Of the 196 independent countries in the world today, each have their own set of export and import controls, taxes, duties, and regulations.  Each are different, and it is not unusual for professionals in the industry, like DHL and Federal Express, to run into problems.

Mistakes, even ones that could be viewed as minor or insignificant, can be costly.  For example: 

  • University of Massachusetts at Lowell was fined $100,000 for shipping an "EAR99" atmospheric testing device to Pakistan. This wouldn’t ordinarily be a problem, but the recipient was identified on the U.S. Department of Commerce Entity List as ineligible to receive any items subject to the Export Administration Regulations (EAR).  In addition, UMass Lowell also was put on 2 years probation.  
  • Massachusetts Institute of Technology (MIT) sent two shipments of experimental equipment to Italy on two Carnet's (which allow temporary import without duty or VAT). All the material was sent back to the US — but on one of the carnet's, not both as originally shipped.  As far as Italian and US Customs are concerned everything that shipped on the carnet that was not used is considered to still be in Italy, and MIT owes US$29,924.31 in VAT.
  • A researcher in Europe sent white phosphorous to an MIT Principal Investigator as a gift.  In addition to being hazardous, it is also used to make methamphetymine which is controlled by U.S. Drug Enforcement Agency. It shipment sat in Customs storage, incurring storage fees of $200/day because MIT could neither receive it nor send it back.
  • MIT returned an instrument to its manufacturer in the Netherlands for repair. Since it was not set up as a temporary import, FedEx paid the import VAT (about $3,000) for MIT, and then sent MIT the bill for reimbursement. 

The University Community is responsible for ensuring compliance with export, import, and economic trade sanctions, as well as other shipping requirements.  NYU's Chief Global Compliance Officer will provide support for any University export/import transaction.  Any University Community member who chooses to not consult with the Chief Global Compliance Officer may be held personally liable for violations of federal regulations. 

The Chief Global Compliance Officer will work with the University department in determining export classifications, which can be accomplished by: obtaining the information from the manufacturer/vendor; making a self-determination; or submitting a formal request to the appropriate U.S. Government agency for classification determination.  Once the classification has been determined, the Chief Global Compliance Officer may then advise on licensing requirements; evaluate possible exceptions/exemptions; provide additional guidance.