Whenever possible the University prefers to rely on manufacturers to provide the export control status of items and software being obtained through a procurement activity. Purchasers within Procurement and Supplier Diversity Services handle all procurements valued at $5000 or more or that requiring a contract with the University; smaller value purchases are handled by purchasers in research, academic, or support offices.
The University’s standard vendor contract now includes a term requiring vendors to notify the Office of Export Controls (OEC) and receive authorization prior to delivering any defense article or service subject to the International Traffic in Arms Regulations (ITAR) to the University. University purchasers are instructed to require all vendors, whether or not contracted, to identify defense articles prior to delivery. Purchasers are required to request the Export Control Classification Number (ECCN) or US Munitions List (USML) category for any items they are procuring if they have reason to believe the items will be subsequently exported.
In cases where the vendor does not know the export control status of an item (e.g. when the vendor is not the manufacturer) or refuses to provide export control information to the University, OEC will perform a self-determination based on the available information. In cases where doubt exists as to the jurisdiction of the item(s), the University will either decline to purchase or will proceed with the purchase and protect the item as a defense article until it is conclusively shown to be subject to the Export Administration Regulations (e.g. through a formal response to a commodity jurisdiction or advisory opinion request).
Purchases valued at <$5000 may be made by using a UVA Procurement Card (P-card) if otherwise eligible under institutional policy and procedures. All individuals issued a P-card are required to complete initial and annual refresher training; this training informs them of their responsibility to request export control information from vendors prior to placing an order and to notify OEC prior to proceeding with the purchase of any ITAR controlled items (defense articles).
EXPORT CONTROL NOTICES
Should an export control notice be included with the shipped items, please forward it to OEC through campus mail (PO Box 400200) or scan in and send it as as an email attachment (export-controls@virginia.edu). If the notice states that an item is subject to the Arms Export Control Act, ITAR, or Department of Energy export control regulations (10 CFR Part 110 or 10 CFR Part 810) the recipient should immediately secure the subject item from access by foreign nationals and notify OEC (phone: 434-982-1539 or 434-924-0855; email: export-controls@virginia.edu) for assistance.