Covid-19 and Export Controls
Covid-19 Export Control Updates
The SARS-CoV-2 virus and genetic elements (e.g., chromosomes, genomes, plasmids, transposons, vectors, and inactivated organisms containing recoverable nucleic acid fragments) are controlled under the Commerce Department’s Export Administration Regulations (EAR). Currently, a license is required for export to certain countries and “restricted parties” (including “restricted universities”).
If you plan to send SARS-CoV-2 virus or genetic elements outside the U.S., please contact RCT as early as possible in order to avoid unexpected delays in your research project. RCT will work with you to determine whether an export license is necessary.
The Commerce Department has informed the public that additional export restrictions may be imposed on SARS-CoV-2 within the coming months. RCT is monitoring the situation closely and will update this page as necessary.
The U.S. Commerce Department has also imposed additional export restrictions on Middle East respiratory syndrome-related coronavirus (MERS). As a result, MERS is subject to stringent export license requirements. If you plan to send MERS outside the U.S., please contact RCT as early as possible in order to avoid unexpected delays in your research project.
Certain non-publicly available third party data may be subject to U.S. export control restrictions. Access to this data from outside the U.S. may require an export license or other authorization. If you are outside the U.S. and require access to third party data that are not publicly available or are subject to confidentiality agreements, non-disclosure agreements, or other dissemination restrictions, please contact RCT at email@example.com to determine whether export restrictions apply.
If you are located within a comprehensively sanctioned country and require remote access to non-publicly available third party data, please contact RCT at firstname.lastname@example.org to discuss U.S. sanctions restrictions and license requirements.
Effective April 10th, 2020, the U.S. Government has imposed an export ban on certain personal protective equipment (PPE). The export ban covers the following:
- N95 respirators;
- Other filtering face piece respirators;
- Elastomeric, air-purifying respirators and appropriate particulate filters/ cartridges;
- PPE surgical masks;
- PPE gloves or surgical gloves.
The rule restricts exports of the covered PPE outside the U.S. without FEMA authorization. Shipments of covered PPE that do not have prior approval can be seized and held by U.S. Customs and Border Protection.
Although the export ban is effective for 120 days (until August 10th), it may be extended beyond this date. In addition, the rule may be expanded to cover additional medical equipment (e.g., ventilators, certain medicines, sanitation or sterilization equipment or materials).