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Import and Export Permitting Can Be Complicated

Biological materials imported into the US or exported out of the US may be subject to permitting requirements through various agencies, including the Centers for Disease Control (CDC), United States Department of Agriculture (USDA), and US Fish and Wildlife (FWS). Common permits required by these regulatory agencies include CITES permits, APHIS permits, EAIPP permits, and export licenses.  For example, the USDA Animal and Plant Health Inspection Service’s Biotechnology Regulatory Services (BRS) requires a notification or permit for the importation of certain genetically engineered organisms. 

Biological materials are not the only materials subject to import/export regulation.  The EPA regulates the importation of new chemicals through the Toxic Substances Control Act (TSCA).  There are extensive regulations surrounding this topic, but a pre-manufacture notification may be required prior to importing any chemical not already listed on the TSCA inventory.  Various items exported from the United States may be subject to export controls through the Department of Commerce Bureau of Industry and Security. 

Some import and export permits are issued to individuals, while others are issued to companies.  Many times, import and export permits are needed on short notice based on research needs.  Unfortunately, there are long lead times associated with some of these permits so applications should be submitted as soon as possible to avoid delays.  Educating all employees on the possibility of import/export permitting requirements will help eliminate situations where a material is needed, but the shipment is delayed due to waiting for the appropriate permit. 

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