Compliance with export controls for physical shipments is a shared responsibility, involving the Office of Export Controls (OEC), CU Mail and Package Services (CU Mail), and the CU-affiliated individual initiating the shipment.
Export controls apply to almost any physical item shipped from the University to a foreign destination, regardless of whether the item is sold, donated, loaned, or used in the field for research. Even items shipped to a CU employee, for only temporary use abroad, as well as items shipped as part of a fundamental research project, must be cleared and documented for export controls compliance. Although the majority of items will not likely require an export license, there are still requirements to file the appropriate electronic export information (EEI) describing the shipment, to classify the item according to relevant rules, and to assess the intended foreign end-user.
Shipments to high-risk countries (see high-risk country list), and foreign shipments valued over $2500, must be approved by OEC prior to leaving campus, and must be coordinated through CU Mail.
When seeking OEC approval and coordinating through CU Mail, the CU-affiliated person preparing the shipment must provide the following information:
Export controls review must be accomplished regardless of whether the item will be processed and shipped through CU Mail Services or via an outside facilitator conducted from an individual account by personnel from an institute, department or campus office. CU policy allows some flexibility in how this review can be accomplished, depending on who initiates and facilitates the shipment and where it is going.
Failure to secure compliance under the University's export policy prior to shipment, makes the shipment outside the scope of CU employment. This may have repercussions when determining liability and consequences for export control violations.