PURCHASE:
The seller is responsible for certifying whether an item “is” or “is not” export controlled. This is known as making an export determination.
Vendors may supply items, data or services that are subject (fall within the federal regulations) to subject to the Export Administration Regulations ((ECCN) and Export Administration Regulation (EAR99))or The International Traffic in Arms Regulations (ITAR) – eCFR :: 22 CFR Chapter I Subchapter M — International Traffic in Arms Regulations. Purchase orders/or requisitions may contain language that characterize items, data or services as sensitive or restricted information. Purchasers should pay attention to key words and phrases such as “export-control”, “controlled or export-controlled item”, “ITAR”, “Commerce Control List”, “CCL”, “restricted”, “License-required” and contact OPRC if such language is present.
The ORPC can assist with the screening of items, data or services prior to domestic and foreign shipments of goods, or transmission of export-controlled software or technology. In addition to the screening an evaluation of the end-use and end-user should be done to ensure it does not result in an activity prohibited by any U.S. export regulations, or other restriction.
TRANSFERS:
The ORPC should be consulted for an export review when property is transferred to a foreign country either because it is no longer needed, or for repair or modification. Such transfers are subject to export control rules.