The Seller is responsible for certifying whether an item “is” or “is not” export controlled.
Vendors may supply items, data or services that are subject (fall within the federal regulations) to subject to the Export Administration Regulations or the International Traffic in Arms Regulations. Purchase order and/or requisitions may contain language (see sample here) that characterize items, data or services as sensitive or restricted information.
The ORPC can assist with the screening of items, data or services against the Consolidated Screening List 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.
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.