Export control, import permits and biosecurity

We screen every order before it ships: destination, end user, end use, and the material itself. We tell you at quotation stage which permits we believe apply to your shipment, and we ask for the permit number before we release goods where one is required. We are not your customs broker or regulatory consultant, and we cannot obtain a permit issued to your institution on your behalf. We flag the requirement at quotation stage.

The regimes below most commonly stop a shipment of living or frozen biological material. The list is not exhaustive and is not legal advice.

You hold the import permit. Import permits are issued to the receiving institution, at the receiving address, for a defined material and often for a defined period and quantity. We cannot hold one for you, and a permit issued to us would not cover a shipment to you.

You are responsible for:

• determining which import authorisations apply in your jurisdiction to the material described on the quotation;
• obtaining them before the shipment date, and giving us the permit number and a copy where required for the airway bill;
• ensuring the permit covers the material, quantity and receiving address on the order. A permit for a different line, a lapsed permit, or a permit naming a different building will fail at the border;
• telling us about any import restriction, licensing requirement or institutional receiving procedure that affects the shipment;
• customs duties, import taxes, brokerage fees and inspection charges in your country, unless the quotation says otherwise.

What we do on our side:

• flag at quotation stage which regimes we believe apply, based on the material and the destination;
• obtain from the supplier the documentation the shipment needs to travel, health certificates, origin statements, serum origin certification, species and strain identification;
• hold the shipment until a required permit number is provided;
• state where we do not know the requirements for a destination we have not shipped to before.

Permit lead times run to weeks, and in some jurisdictions months. Start the application at quote request stage.

The cold chain is regulated independently of the biology inside it. Shipments move under IATA dangerous goods regulations for air transport and the corresponding surface rules.

• Dry ice ships as UN 1845, a class 9 dangerous good. Quantity is declared on the airway bill, packaging must vent, and aircraft loading limits apply. A mis-declared shipment is refused by the carrier.
• Liquid nitrogen dry shippers ship as vapour-phase vessels with the nitrogen fully absorbed into the internal medium. Correctly prepared they are not classed as shipping liquid nitrogen. A partially charged, over-filled or damaged shipper is classed as such and is refused. Dry shippers are returnable assets with their own return logistics and deadlines.
• Biological substances ship as UN 3373 category B where applicable, in triple packaging, with a trained shipper's declaration. Category A infectious substances fall under a more restrictive regime and are not brokered.
• Packaging and declaration are performed by trained personnel at the supplier or their logistics provider, as a certification requirement.

Your facility must be able to receive these. Dry ice and dry shippers create asphyxiation risk in confined spaces, and some receiving docks, mail rooms and building policies prohibit them. The quote form asks what your facility can receive. Courier windows, temperature logging and arrival procedure are at shipping, cold chain and handling.

Before an order is accepted we screen the destination country, the receiving institution, and the named end user against applicable sanctions and denied-party lists, and we assess whether the material or associated equipment is subject to export control in the jurisdiction it ships from.

Where a licence is required, the shipment does not move until it is granted. Where a destination or party is restricted, we decline and notify you.

Screening requires us to know who the end user is. This is one of the situations described in confidentiality and your specification where anonymity is not available. We cannot screen an unnamed party, and a supplier cannot accept an unnamed end user on a controlled line. This is stated before anything is circulated.

You must not re-export, transfer or divert material in breach of any applicable export control or sanctions law, and you must not transfer it to a restricted party. If you plan to move material on to a collaborator in another country, notify us. That is a separate export with its own permit requirements, and it is your responsibility once the material is yours.

Screening performed:

• ask what the material is for, on every request;
• decline requests where the stated or apparent end use is a weapons application, a deliberate-release application, or anything intended to cause harm;
• decline requests for select agents, category A infectious substances, and controlled toxins, which are not brokered;
• route requests that touch on dual-use research of concern back to the requester's institutional biosafety oversight;
• treat an unwillingness to identify the end user or the end use on a sensitive request as a reason to decline;
• keep records of screening decisions.

Limits of screening:

• we are not a biosecurity authority, and our screening is not a substitute for your institution's oversight;
• we do not run sequence screening of the kind synthesis providers apply to nucleic acid orders. We broker cells, tissues, devices and services, not synthesis;
• we cannot verify what happens to material after delivery, beyond the contractual restrictions that travel with it.

Disclose a dual-use dimension at quote stage. A request that does not state the end use will be declined.

We will not supply:

1. into a jurisdiction where supply would be unlawful, or to a sanctioned or denied party;
2. where a required import permit or export licence is absent, lapsed, or does not cover the material or the address;
3. select agents, category A infectious substances, controlled toxins, or material on a national select agent or controlled pathogen list;
4. where the intended end use is prohibited by no medical, clinical or diagnostic use;
5. where we have reasonable concern about the end use, including weapons or deliberate-release applications;
6. where the receiving facility cannot meet the containment level the material requires, or cannot receive the cold-chain format;
7. where the supplier's own conditions of sale prohibit supply to that destination or end user;
8. where the chain of custody or consent basis for human-derived material cannot be documented adequately.

Where we decline, we state the reason to the extent lawfully permitted, and refund anything paid for the declined scope. Where a compliant route exists at longer lead time and higher cost, it is described.

Five items reduce delay.

1. State the destination country at quote stage. It determines which suppliers can serve you and which permits apply.
2. Start permit applications at quote request stage. Permit lead times often exceed production lead times.
3. Involve your biosafety officer and research office early. They hold your institution's receiving procedures, licences and committee calendar.
4. State what your receiving dock can accept. Dry ice, dry shippers, live cultures, and material at a given containment level.
5. Send permit numbers on receipt. Shipments are held pending them.

Nothing on this page is legal or regulatory advice. It describes how we operate and the requirements most often encountered. Your institution's regulatory affairs function is the authority on your obligations.

Enquiries before ordering: [email protected]. For a live order, [email protected] with the reference.