Introduction
The following guidance and decision matrix has been established to assist faculty, staff, and students in the planning process for an international shipment of tangible/physical items. This guidance has been established to advise on the proper procedures to ensure compliance with Export Control regulations and requirements as defined in the Lehigh University Export Control Compliance Manual.
Shipment of a tangible item to a destination outside of the United States (“international shipment”) is considered an Export. International shipments include, but are not limited to, equipment, materials, software item(s), etc. These requirements apply regardless of whether the item is sold, used for collaborative or individual research, loaned, donated, or shared with an entity or individual outside of the U.S., even if only temporarily.
All international shipments must be reviewed prior to shipping to ensure that a license is not required and that items are not being exported to a denied or restricted entity or individual. Export control laws and regulations may require that Lehigh University obtain a license for the export of certain items. The Office of Research Integrity will assist you in assessing the need for a license and in preparing and filing required export and shipping documentation.
Restricted Party Screening
The initial step in the process is to contact the Office of Research Integrity to perform restricted party screening. Restricted party screening is required for all international transfers regardless of data type or international destination(s). Please allow at least 5-7 Business Days for review and response before engaging in the planning and shipment of the item(s). Contact the Office of Research Integrity to request restricted party screening of the entity or individual recipient and/or end-user.
Decision Matrix
The next step in the process is to review the decision matrix. After the restricted party screening has been completed by ORI, please use the following matrix to determine whether the information can now be shipped or if further review is required by the Office of Research Integrity. When reviewing the decision matrix it will be helpful to have the following information available:
- Complete description of the item(s) to be shipped internationally, including use, intent, and purpose of the international shipment
- Export Control Classification Number (ECCN) or United States Munitions List (USML) Category, if available (ECCNs and/or USML Categories can often be found on manufacturer’s websites or by contacting the manufacturer or vendor directly)
- Country of destination
- Name of recipient or end-user of item, including the name of the individual and the entity with which they are affiliated or employed
- Method of transport or shipping to be used
- Whether the item is connected to the performance of an external sponsored research award, and if so, the sponsor agency name and award number
The decision matrix is intended to collect information from the shipper (faculty, staff, or students) and self-certify about the “who, what, when, where, and how” of the international transfer.
If the answer to all of the questions below are NO, the shipper may proceed with the international transfer. If the answer to any of the questions below are YES, the shipper must email the information to the Office of Research Integrity at inexport@lehigh.edu for further review.
| International Shipments Decision Matrix | Does the international shipment of this item need further review? | |
| YES; contact the Lehigh Office of Research Integrity | NO; proceed with transfer | |
| Did Restricted Party Screening performed for this shipment result in a match? | Yes | No |
| Does the item being shipped have an Export Control Classification Number (ECCN) or USML Category? | Yes | No |
| Is the shipping destination on the list of sanctioned countries found here? | Yes | No |
| Does the end use of this item have a military or space application? | Yes | No |
| Is there any indication that usage of this item could compromise United States national security or foreign policy goals, regardless of the shipper's stated use? | Yes | No |
| Is the item owned by a third-party (not Lehigh)? | Yes | No |
| Is shipment of the item connected to the performance of an externally sponsored research project (e.g. DOE, DOD, DARPA) | Yes | No |
Record Retention for International Transfers
All records, including emails and expense receipts, associated with any international shipment must be retained as required by the applicable export control regulations for a period of five (5) years from the date of shipment.