Federal export control regulations are only one factor of many to consider when shipping or carrying equipment for temporary use abroad. Both U.S. and non-U.S. governments also impose a variety of customs and import rules that may apply. When planning to ship or carry items for temporary use in a location outside the U.S., University personnel should consider obtaining one of the following documents, which can ease the import process and reduce potential risks and headaches.
ATA Carnet for Temporary Export
For high-value items moving internationally, we recommend obtaining an ATA Carnet. The Carnet is a globally accepted customs document, often informally referred to as a “passport for goods.” Goods covered by a Carnet generally may enter most countries with little-to-no duties or taxes, and without the need for a temporary import bond. The cost of obtaining a Carnet varies, depending on the value of the goods covered, but is in the $200-$500 range.
U.S. Certificate of Registration of Goods (CBP Form 4455)
When an item temporarily exported is eventually brought back into the U.S., Customs and Border Protection (CBP) personnel may treat the return as a dutiable import of a foreign-origin item, if they believe there is insufficient proof that the item was exported from the U.S. in the first place. Prudent exporters can eliminate this risk with the use of the U.S. Certificate of Registration of Goods (CBP 4455).
In short, the person planning a temporary export completes the first portion of the form and presents it and the relevant articles to the nearest CBP office. CBP personnel inspect the articles and countersign the form, which the exporter retains. When the temporarily exported articles come back to the U.S., the completed Form 4455 is presented as signed confirmation from both the exporter and CBP that the items are not foreign-origin.
There is no fixed fee for using a Form 4455, but of course some effort is required to present the paperwork and articles intended for temporary export to the nearest CBP operation (usually at an international airport or maritime port).
Note: CBP accepts ATA Carnets as an alternative to the Form 4455, for import purposes.
University of Minnesota Letter of Ownership and Intent
On request, the University’s Export Controls Officer will issue a formal letter documenting the ownership, use, and planned movement of University equipment. This letter is often useful when dealing with U.S. and non-U.S. customs personnel, although there is no guarantee it will be sufficient by itself, and we have encountered one situation in which CBP strongly stated that a Carnet or Form 4455 is preferred. In other words, while obtaining this letter is free, fast, and convenient for University personnel, the letter might not always meet the expectations of individual customs officials, who operate with a fair amount of discretion.
Record Retention Requirements
Federal regulations require that exporters keep records of exports—including temporary exports—for a minimum of five years after the date of the shipment. These records include any relevant Carnets, forms, letters, pro forma invoices, airway bills, export filings, and associated communications.