International Shipping Policy

  1. Purpose
    The purpose of this Policy is to specify Clemson University’s commitment to full compliance with all Export Control, Trade, and Transportation Sanctions laws and regulations as they apply to international shipments, and to outline processes and procedures for institutional review of international shipments prior to shipment.
  2. Scope
    1. This Policy applies to all university personnel, employees, students, visitors, courtesy appointments, and any other individual conducting research, academic, operational, or business activities on behalf of Clemson University, regardless of whether such activities are conducted physically at Clemson University, physically at another location, or virtually.
    2. This Policy further applies to international shipments of:
      1. Products (items, commodities, equipment, materials, software) regardless of whether the products are the result of fundamental research
      2. Works of Art (artwork, artifacts, antiquities)
      3. Biologics or Chemicals (including genes and genetic material), Radioactive Materials, and Dry Ice
      4. Plants, Animals, or Human Tissue (including insects, soil, seeds, and human/ animal remains)
      5. Controlled substances (including prescription medicines, drugs, vaccines, vaccination kits, etc.)
      6. Documents containing technical and/or proprietary data (i.e. non-public data)
  3. Policy Statement
    1. Clemson University will comply with all U.S. federal Export Control, Trade Sanction, and Transportation regulations when shipping items, commodities, equipment, materials, substances, biologics, antiquities, artifacts, artwork, software, and/or technical data (collectively, “items”) to an international destination/party. These laws govern:
      1. Items that we, as a U.S. institution, can export (i.e. transfer) out of the country
      2. Shipments which require an export license or other authorization
      3. Shipments which require customs declarations, filings, and other documentation
      4. Shipments which require hazardous materials protocols
    2. Individuals shipping on behalf of Clemson University must ensure that all necessary institutional reviews are completed PRIOR to submitting an international shipment. Institutional reviews may include (but are not limited to): Export Control, Occupational and Environmental Safety, Sponsored Programs, Research Compliance, CCIT, General Counsel, and any department holding a financial or legal interest in the items to be shipped.
    3. Review Process
      The International Shipping Review Process is found here. Shippers must follow this process prior to shipping any item internationally.
    4. Record Keeping
      All records and documentation (including communications related to internal reviews, waybills, commercial invoices, statements of shipping fees, receipts for shipping, Restricted Party Screening results, etc.) must be maintained by the shipper for at least five (5) years from the date of shipment.
    5. Questions related to the International Shipping Review Process should be directed to the Export Control Office at exportcontrol@clemson.edu.
    6. Sanctions for Non-Compliance
      1. U.S. Government agencies strictly enforce export control and trade sanctions regulations through substantial civil and criminal penalties, federal debarment, and revocation of export privileges. Agencies have full audit and oversight authority.
      2. Consequences for violations by university personnel, employees, students, visitors, courtesy appointments, and any other individual conducting research, academic, operational, or business activities on behalf of Clemson University can include discipline up to and including termination and dismissal, depending on circumstances.
  4. Definition(s)
    1. Shipper: Individual shipping on behalf of Clemson University.
    2. Shipping company: Entity providing shipping services.
  5. Additional Resources
    1. International Shipping Review Process
  6. Responsible Department/Division
    Procurement and Business Services, 864-656-2390
  7. Published Location
    https://www.clemson.edu/procurement/faculty-staff/shipping/internationalshipping.html
  8. Approval & Revision History
    1. President Approval: August 9, 2021
    2. Originally Issued: August 9, 2021