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Effective: November 10, 2025 (interim)

Approved by: Justin Schwartz, ChancellorÌý

Policy Owner: Senior Vice Chancellor for Research and InnovationÌý

Policy Contact: Office of Export Control (OEC), exportcontrolhelp@colorado.eduÌýÌýÌý

Supersedes: N/AÌý

Applies to: Faculty, staff, students, CU º£½ÇÉçÇø affiliatesÌý

I. IntroductionÌý

The º£½ÇÉçÇø (CU º£½ÇÉçÇø) engages in many international collaborations as part of its academic and research mission. These collaborations often involve shipping or hand-carrying items internationally. CU º£½ÇÉçÇø faculty, staff, students, and affiliates who intend to ship or hand-carry items outside the United States for CU º£½ÇÉçÇø business or purposes must comply with U.S. Export Control Laws and Regulations, including the Department of Commerce’s Export Administration Regulations (EAR), the Department of State’s International Traffic in Arms Regulations (ITAR), and the regulations administered by the Treasury Department’s Office of Foreign Assets Control (OFAC). This policy applies to all CU º£½ÇÉçÇø-related international shipments and hand-carried items. This includes shipments that originated from CU º£½ÇÉçÇø and shipments associated with CU º£½ÇÉçÇø. This policy does not apply to shipments or hand-carried items that are unrelated to CU º£½ÇÉçÇø.ÌýÌý

II. DefinitionsÌý

Hand-carry: To transport an item by hand or in luggage, rather than shipping via courier.

International shipment: Any item leaving the United States, whether by courier or carried by an individual during travel (hand-carried).

International shipper (shipper): A CU º£½ÇÉçÇø faculty member, staff member, student, or affiliate who is shipping or hand-carrying a CU º£½ÇÉçÇø-related item internationally.Ìý

III. Policy StatementÌý

CU º£½ÇÉçÇø is committed to promoting and protecting its ability to perform research domestically and internationally, which requires adherence to U.S. Export Control Laws and Regulations. The Office of Export Control (OEC) and CU Distribution Services are partnering to facilitate and manage international shipments and reduce the risk of export violation by ensuring shipment reviews are conducted in compliance with federal regulations and this policy.ÌýÌýÌý

This policy applies to shipments made via courier, shipments made via freight, and domestic shipments with an ultimate end location that is international. This policy also applies to hand-carried items including, but not limited to, IT devices and research-related items, such as equipment, materials, data, and biological or chemical substances. Any transfer of project information, equipment, materials, or technology outside of the U.S. by any method may be subject to export control restrictions and may require an export license or be prohibited, depending on the item, destination, recipient, and end use.ÌýÌýÌý

Failure to follow the international shipping process or international hand-carry process, or failure to provide complete and accurate information to CU Distribution Services or OEC may lead to corrective or disciplinary action, up to and including termination of employment or affiliation with CU º£½ÇÉçÇø.ÌýÌý

IV. Roles and ResponsibilitiesÌý

1. International shipper:
   1. For international shipments, the shipper must:
      1. Follow the international shipping process outlined on the CU Distribution website;
      2. Provide complete and accurate information to CU Distribution Services; and
      3. Provide additional information to CU Distribution services and OEC as requested.
   2. For international hand-carried items, the shipper must:
      1. Follow the international hand-carry process outlined on the OEC website prior to travel;
      2. Provide complete and accurate information to OEC; and
      3. Provide additional information to OEC as requested.Ìý

2. CU Distribution Services:
   1. Publish and maintain the international shipping process on the CU Distribution website, following OEC export control guidance;
   2. Receive and promptly process international shipping requests, triaging to OEC when the intended shipment requires review, pursuant to U.S. Export Control Laws and Regulations;
   3. Finalize all international shipment documentation.ÌýÌý

3. Office of Export Control:
   1. For international shipments, OEC will:
      1. Provide and publish export control guidance on the international shipping process; and
      2. When CU Distribution Services determines that OEC review of an international shipping request is required for compliance with U.S. Export Control Laws and Regulations, OEC will:
         1. Review shipment recipients, contents, destinations, and other records provided by the shipper or CU Distribution Services for compliance with U.S. Export Control Laws and Regulations;
         2. If an export license is required, advise the shipper and CU Distribution Services of the determination; and
         3. Approve or deny the shipment.
   2. For international hand-carried items, OEC will:
      1. Provide and publish export control guidance on the hand-carry process; and
      2. Conduct OEC Review following federal guidance and regulations.
      3. If an export license is required, advise the shipper of the determination; and
      4. Approve or deny the hand-carry.Ìý