The University of Arizona

Purchasing and Export Control

Export Control

export@email.arizona.edu

Kay Ellis
Director, Export Control Program
ellisk@email.arizona.edu
(520) 626-2437

Keith Corson
Export Control Analyst
kcorson@email.arizona.edu
(520) 626-5865

Wendy Epley
Export Control Analyst
wepley@email.arizona.edu
(520) 621-0348

 

Street Address
1618 E. Helen Street
Tucson, AZ 85721

Mailing Address
PO Box 210409
Tucson, AZ 85721


Announcements

Memo from Provost Regarding Travel to Iran

The following provides guidance on processing University of Arizona purchases in accordance with U.S. Export Regulations.

P-Card Purchases under $5,000
Requisition Forms - Purchases over $5,000
Shipping and Receiving

P-Card Purchases under $5,000

Purchases of equipment, tooling, or services in an amount less than $5,000 are made using University P-Cards. P-card purchases can be made by department personnel (purchaser).

P-card purchases do not require prior review by Procurement and Contracting Services (PACS). The purchaser will conduct a Visual Compliance screening of a vendor if the purchase is for an export control project.

  • If the screening result is an exact match (“hit”) to the potential vendor, stop the purchasing process and forward the screening results to UECP for review.
  • Purchasing from denied parties is prohibited, therefore, the purchasing process cannot move forward until approval from UECP is received.

Purchaser shall request the export classification - either ECCN or ITAR Category - from the vendor before placing the order for equipment/hardware, if:

  • The equipment/hardware is for an export controlled project, which has a Technology Control Plan in place,
  • The equipment /hardware will be shipped or taken outside the U.S., and/or
  • The equipment/hardware has an obvious military or space capability, or is a type of laser, sensor, infrared camera, or high-performance computer. Please contact the Export Control Program if you have any questions regarding equipment/hardware export controls.

If placing an order for a vendor to manufacture an ITAR controlled article, the vendor is required to complete the Export Control Vendor Certification Form if one is not already on file.

  • The original Export Control Vendor Certification Form will be kept on file with the department making the purchase, in accordance with University record keeping requirements.
  • Purchaser will notify the department IT personnel to create a Secure Vendor Folder if it is decided to use the secure folder method for transmitting data to the vendor:
    • A folder within the department IT Secure Vendor Folder will be created with a username and password unique to the vendor.
    • Authorized department IT personnel will e-mail vendor the link to the website for the Secure Vendor Folder connection.
    • Authorized personnel will telephone the vendor to provide username and password to the Server.
  • Optionally, ITAR data and documents may be mailed or given to the vendor via an encrypted USB flash drive, or if hard-copy documents are mailed to the vendor, each page of the document must be marked “ITAR controlled: do not distribute to non-U.S. persons” prior to mailing.

    At no time should ITAR controlled technical data be emailed to a vendor.

Requisition Forms - Purchases over $5,000

Purchases of equipment, tooling, or services in an amount greater than $5,000 require the department personnel (purchaser) to submit a requisition form to the PACS office.

In addition to the requisition form, purchasers are required to provide three (3) supplier sources to the PACS office. If only one source is available, a Sole Source Verification Form must be submitted.

Prior to placing an order, the purchaser should reference the UAccess vendor file to verify that the vendor has been approved and has an established account.

If the vendor is not listed on the approved vendor’s list, a W-9 form must be submitted to PACS in order to establish an account and account number for the new vendor.

  • PACS will create an account and account number within the university system for the new vendor and conduct Visual Compliance Screening of the vendor at that time.
  • Visual Compliance Screening results are also conducted for all new vendors on a nightly basis through the Visual Compliance administrative account with Arizona State University (ASU).
  • PACS will receive an e-mail from ASU administrators and the Visual Compliance system if a vendor has been added to any denied parties lists. Business will no longer be conducted with that vendor and they will be removed as an approved vendor.

The purchaser shall request the export classification (either ECCN or ITAR Category) from the vendor before placing the order for equipment/hardware if:

  • The equipment/hardware is for an export controlled project (a technology control plan is or will be implemented);
  • The equipment /hardware will be shipped or taken outside the U.S., or
  • The equipment/hardware has an obvious military or space capability, or is a type of laser, sensor, infrared camera, or high-performance computer. Please contact the Export Control Program if you have any questions regarding equipment/hardware export controls.

If placing an order for a vendor to manufacture an ITAR controlled article, the vendor is required to complete the Export Control Vendor Certification Form if one is not already on file. For new vendors, forward a copy of the Export Control Vendor Certification Form to PACS. These forms will be kept on file by PACS in accordance with university record keeping requirements.  Manufacturing information may include design specifications, drawings, blueprints, models, plans, etc. related to the item.

  • A copy of the Export Control Vendor Certification Form will be forwarded to PACS if vendor is new and requires account establishment.  These forms will be kept on file by PACS in accordance with university record keeping requirements.
  • The original Export Control Vendor Certification Form will be kept on file with the department making the purchase, in accordance with University record keeping requirements.
  • Purchaser will notify department IT to create a Secure Vendor Folder if it is decided to use the secure folder method for transmitting data to the vendor:
  • Authorized personnel will telephone the vendor to provide the username and password to the Server.

Optionally, ITAR data and documents may be mailed or given to the vendor via an encrypted USB flash drive, or if hard-copy documents are mailed to the vendor, each page of the document must be marked “ITAR controlled: do not distribute to non-U.S. persons” prior to mailing.

At no time should ITAR controlled technical data be emailed to a vendor.

Shipping and Receiving

The Export Control Program should be notified before the export of any articles outside the U.S.

  • Equipment may not be shipped outside of the U.S. until a determination has been made as to whether an export license is required.
  • The Shipper shall work with the University Export Control Program (UECP) for assistance.

ITAR controlled equipment and some EAR controlled equipment will require prior government authorization in the form of a license or exemption before it can be exported.

Domestic shipments of export controlled equipment do not require prior government approval but should be identified as such if ITAR controlled, as described below.

If shipping ITAR controlled equipment, the inner packaging of the box or container will be marked “ITAR CONTROLLED- NO FOREIGN PERSON ACCESS” and will be placed inside of a secured crate or container for shipping or transporting.

Only the Export Control Program can obtain the necessary government approvals and subsequently advise the shipper of the required information to be included on the shipping documents.

Shipping documents received should be checked for export classification and/or export control clauses. All shipping documents related to the export of an item that requires a license or license exemption are to be maintained for a period of five (5) years from license expiration date in accordance with U.S. export record keeping requirements.

ITAR controlled equipment received from vendors should be inspected by the University of Arizona recipient and verified against the purchase order.

Shipping documents received should be checked for export classification and/or export control clauses.

ITAR controlled equipment should be delivered directly to purchaser, or quarantined in a limited access area until delivered to purchaser.

Questions regarding the procurement of export controlled articles should be addressed to the Export Controls Program at export@email.arizona.edu.