Biological, Hazardous, or Radioactive Material

Some items are hazardous, and need to be packaged and labeled appropriately:

  • Biologicals
  • Chemicals
  • Batteries and fuel cells
  • Radioactive

The EHS Office provides services to assure that these items are shipped by air, land or sea, in accordance with all regulatory requirements. These requirements are separate from, and in addition to, any export control requirements.

Does my biological material need an export license?

ITAR

"Biological agents and biologically derived substances specifically developed, configured, adapted, or modified for the purpose of increasing their capability to produce casualties in humans or livestock, degrade equipment, or damage crops" are USML Category XIV(b), and require a license to export from the US. Contact MIT's Export Control Officer and EHS.

EAR - Commerce Control List

Specified human and zoonotic pathogens and toxins are ECCN 1C351, and are very likely to need an export license. Contact MIT's Export Control Officer and EHS.

Specified animal pathogens are ECCN 1C352, and are very likely to need an export license. Contact MIT's Export Control Officer and EHS.

Specified plant pathogens are ECCN 1C354, and are very likely to need an export license. Contact MIT's Export Control Officer and EHS.

Genetic elements (including chromosomes, genomes, plasmids, transposons, and vectors, whether genetically modified or unmodified, or chemically synthesized in whole or in part) associated with the pathogencity of the microorganisms referred to above, or that contain nucleic acid sequences coding for any of the toxins referred to above, are ECCN 1C353.a, and are very likely to need an export license. Contact MIT's Export Control Officer and EHS.

Genetically modified organisms that contain nucleic acid sequences associated with the pathogencity of of the microorganisms referred to above or that contain nucleic acid sequences coding for any of the toxins referred to above, are ECCN 1C353.b, and are very likely to need an export license. Contact MIT's Export Control Officer and EHS.

Vaccines against the items referred to above, or immunotoxins containing items referred to above, are ECCN 1C991 and may need an export license. Contact MIT's Export Control Officer and EHS.

Note: gene fragments, chromosome fragments, and nucleic acid sequences for verotoxin-producing e. coli that don't contain coding for the verotoxin or its sub-units are ECCN EAR99.

EAR - End Use

If you know (including awareness of a high current or future probability) that any item will be used in the design, development, production, stockpiling, or use of chemical or biological weapons, it will need an export license. Contact MIT's Export Control Officer.

EAR and OFAC - End User and Country

The destination country may be included in sanctions programs administered by the Treasury Department's OFAC. The recipient may be a restricted party identified on OFAC's Specially Designated Nationals and Blocked Persons List (SDN), the Commerce Department's Entity List, or on another US government restriction list. Contact MIT's Export Control Officer to determine whether the recipient or country are on these lists, and whether a license is required.

Reminder

Technology (technical data, technical assistance) for the development, production, or use of the items referred to above is also subject to EAR, and transfer of technology in the US is a "deemed export" to the country of the receiving party.