Product Classification Certification for External Suppliers

The University of Pittsburgh requests that you, as the vendor/manufacturer of the item(s), supply their U.S. Export Controls Classification. Per 15 CFR 758.3, it is the responsibility of the manufacturer or supplier, not the buyer or freight forwarder, to identify the export controls classification of this item(s) that are in the U.S. trade, i.e. that are being produced, developed, manufactured or sold in the U.S. Neither the buyer nor the freight forwarder is in position to understand the technical assessment of the item(s) and/or the original design intent in order to determine the correct classification.
 
The classification of your item(s) shall pertain to the appropriate U.S. Export Controls regulations:
 
  • Export Administration Regulations (EAR) – for export of dual-use items – administered by the U.S. Department of Commerce, Bureau of Industry and Security (BIS)
     
  • International Traffic in Arms Regulations (ITAR) – for import and export of “inherently” military items – administered by the U.S. Department of State, Directorate of Defense Trade Controls (DDTC) 
     
  • NRC regulations – for import and export of nuclear equipment and material – administered by the U.S. Department of Energy, Nuclear Regulatory Commission (U.S. NRC) 
     
  • ATF regulations – for import and export of alcohol, tobacco, firearms, explosives and arson items – administered by the U.S. Homeland Security, Bureau of Alcohol, Tobacco, Firearms and Explosives (BATFE) 
If your organization is located outside of the U.S., you may use the Wassenaar Arrangement guide for identifying the classification.
 
If, after reviewing the above regulations, you are unsure about the export jurisdiction of your item, you may request a Commodity Jurisdiction determination (CJ) from the Directorate of Defense Trade Controls (DDTC - Department of State) which will determine whether or not the item is covered under the ITAR.
 
If your item is not covered under the ITAR and you believe that your item pertains to the EAR but you are not able to assign a classification number, you may submit a Commodity Classification Request to BIS via the BIS-748P form.
 
We are also requesting that, in addition to the export classification, the U.S. Harmonized Tariff Schedule (U.S.- HTS) is provided.

Please complete the form below if:

  • The item is controlled by ITAR, NRC, ATF; or
  • The items is EAR-controlled item with nX5nn (500 series) nx6nn (600 series) classification; or,
  • There are other export controls on the item.

Note: EAR99 items DO NOT require a completed form.

If there are numerous items, you may send a spreadsheet with the relevant information to TradeCompliance@pitt.edu. A copy of this completed form will be sent to your Pitt Contact listed on the form.

 
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