International travel can intersect with export control regulations based on where you are going, who you will be interacting with and what you are taking with you.
MU International Programs has helpful information about traveling abroad including passport and visa information, health and safety information, etc. Additionally, the UM System has developed an Information Security Travel Standard providing valuable information on protecting university data while traveling internationally.
From an export compliance perspective, there are three key questions to ask.
Where are you going?
If you are going to a sanctioned destination (Cuba, Iran, North Korea, Syria, or the Crimea, Donetsk or Luhansk regions of Ukraine) on university business, contact us as soon as possible. All travel to and activities in these locations require an Office of Foreign Assets Control (OFAC) license. We can help identify if a general license is available or if we need to apply for a specific license from OFAC. Please keep in mind specific licenses can take up to six months to obtain.
Who will you be interacting with?
If you will be visiting or collaborating with others during your travel, a Restricted Party Screening should be conducted. If we already have some type of formal, signed agreement on file with the other party, a screening has already been conducted. Contact us if you need a screening conducted. It is a quick process and helps ensure that the export of physical items, restricted information or provision of any type of assistance follows export control regulations.
What are you taking with you?
Traveling outside the U.S. with certain university items, equipment or technology (regardless of whether this will result in a permanent or temporary export) may require an export license or an export license exception depending on the travel destination and the export classification of the item, equipment or technology. This is true even when your travel is for personal reasons.
The chart below will help you determine the Export Control Classification Number (ECCN) and export license requirements for many common travel items. If you are taking university items not found on the list below or if you are taking confidential or proprietary information with you, we can help determine whether an export license is required. Reach out to us if you have questions.
Export Control Classification Numbers (ECCNs) for Common Travel Items*
|Mass Market Commercial Laptops (HP, Dell, Apple, etc.)||5A992||No License Required (NLR)|
|Cell Phones and Tablets (Android and Apple)||5A992||No License Required (NLR)|
|iPhones and iPads||5A992||No License Required (NLR)|
|AirPods||5A992||No License Required (NLR)|
|Apple Watches||5A992||No License Required (NLR)|
|Jump/Flash Drives (most)||3A991||No License Required (NLR)|
|Garmin GPS||7A994||No License Required (NLR)|
|Bitlocker Encryption||5D992||No License Required (NLR)|
|GoPro Camera||EAR99||No License Required (NLR)|
|Canon Powershot Camera||EAR99||No License Required (NLR)|
|Mass Market Software (Windows, iOS, OS X, Microsoft Office, Adobe Products, Visual Studio)||5D992||No License Required (NLR)|
|Open source software (Linux, Apache)||5D002||No License Required (NLR)|
*Note: Do NOT use the chart above for the following scenarios:
Travel to a sanctioned destination (Cuba, Iran, North Korea, Syria, or the Crimea, Donetsk or Luhansk regions of Ukraine).
Travel to Burma/Myanmar, Cambodia, China, Russia or Venezuela in which the items will not be brought back to the U.S. with you or consumed while overseas.
How to avoid duty & taxes on temporary exports
When an item is temporarily exported and is brought back to the U.S., the U.S. Customs and Border Protection (CBP) may treat the item as an import of a foreign-origin item and require import duties and taxes to be paid upon re-entry into the U.S. Obtaining proof prior to your travel that the item originated in the U.S. is prudent and can be done in several ways:
ATA Carnet: The International Chamber of Commerce defines an ATA Carnet as “an international customs document that permits duty-free and tax-free temporary import of goods for up to one year. It contains pre-prepared unified customs declaration forms to be used at each customs border office and serves as a guarantee to customs duties and taxes.” An ATA Carnet can be used to clear customs in 87 countries and territories. The cost of obtaining an ATA Carnet varies, depending on the value of the goods covered. U.S. Customs and Border Protection provides additional information about how to obtain an ATA Carnet.
Certificate of Registration of Goods (CBP 4455): The U.S. Certificate of Goods (CBP 4455) is issued by CBP and proves that the items originated in the U.S. The person planning a temporary export completes the first portion of the form and presents it and the relevant items to the nearest CBP office (usually at an international airport). CBP personnel inspect the items and countersign the form, which the exporter retains. When the temporarily exported items come back to the U.S., the completed Form 4455 is presented as signed confirmation from both the exporter and CBP that the items are not of foreign origin.
Export Notification Filings
Exports valued at $2,500 or more also require an advanced filing with the U.S. Census Bureau. Generally, things that are only being temporarily exported (i.e., that will return to the U.S. within one year) are exempted from this filing requirement. However, if you are taking university items overseas that will remain in the foreign country and the total value of the items is greater than $2,500, the filing of Electronic Export Information (EEI) may be required several days before your departure. Please contact us a minimum of two weeks before your travel with a list of items you will be bringing, their brand name, a link to the item online, the amount paid for the item, the organization you will be giving the items to and your flight details. We can review in more detail to determine if the EEI needs to be filed and can submit the filing on your behalf.
If you travel outside the U.S. with physical items, materials, technology and encrypted devices, it is your responsibility to ensure that the items, materials and devices do not require an export license or carry any technology that requires an export license. Assistance with determining requirements can be obtained by contacting us.