1. Overview
Scoville Splice complies with all applicable U.S. export control laws and regulations, including the Export Administration Regulations (EAR, 15 C.F.R. Parts 730–774) administered by the Bureau of Industry and Security (BIS), the Office of Foreign Assets Control (OFAC) regulations implementing U.S. sanctions programs, and the International Traffic in Arms Regulations (ITAR, 22 C.F.R. Parts 120–130) to the extent applicable. Users are responsible for their own compliance with applicable export control laws in their jurisdiction.
2. EAR Classification
Scoville Splice genetic construct files are classified under the Commerce Control List (CCL) as follows:
- Standard plant pathway constructs (non-select-agent, non-toxic pathway): EAR99 (no BIS license required for most destinations)
- Constructs involving genes with potential dual-use concern or express toxicity: may be controlled under ECCN 1C353 (Genetic Elements and Genetically Modified Organisms) — each construct's datasheet identifies its ECCN classification
- Certain CRISPR guide sets targeting conserved plant/pathogen genes: may require review for EAR compliance before export
Users are responsible for verifying the applicable ECCN for each construct and determining whether an export license is required for their destination country and end use. Contact scovillesplice@gmail.com for ECCN verification letters.
3. Prohibited Countries and Parties
Scoville Splice does not provide constructs, licenses, or platform access to users in countries subject to comprehensive U.S. sanctions, currently including Cuba, Iran, North Korea, Russia (as to restricted sectors), Syria, and the Crimea region of Ukraine. This list may change; users are responsible for checking current OFAC designations. Additionally, Scoville Splice does not do business with any person or entity on: the BIS Denied Persons List; the BIS Entity List; the OFAC Specially Designated Nationals (SDN) List; the U.S. State Department Debarred Parties List. Platform accounts are screened against these lists at registration and periodically thereafter.
4. End-User Certification
By creating an account or completing a license purchase, you certify that: you are not located in, and will not export constructs to, any comprehensively sanctioned country; you are not a national of a sanctioned country acting on behalf of a sanctioned government; you are not on any U.S. government restricted-party list; you will not re-export constructs to any prohibited party or country without first obtaining any required BIS re-export license; the constructs will not be used in the development, production, or stockpiling of chemical, biological, nuclear, or missile (CBRN) weapons or their delivery systems.
5. Deemed Exports
A "deemed export" under EAR is the release of controlled technology to a foreign national in the United States. Institutions employing foreign nationals who will access Scoville Splice constructs must ensure compliance with deemed export requirements, including obtaining BIS deemed export licenses where required.
6. Reporting and Violations
If you become aware of any potential export control violation involving Scoville Splice constructs, please contact scovillesplice@gmail.com immediately. Scoville Splice takes export control compliance seriously and will cooperate fully with BIS, OFAC, and other regulatory authorities in any investigation. Violations of export control laws can result in civil penalties up to $1 million per violation and criminal penalties including imprisonment.
7. Record-Keeping
Scoville Splice maintains export control records as required by EAR, including records of all electronic transmissions of controlled technology to foreign persons, for a minimum of five years. Users must maintain records of their use and any re-exports of Scoville Splice construct files for a minimum of five years and make them available to Scoville Splice or U.S. government authorities upon request.
8. Export Control Questions
Export control compliance questions, ECCN verification requests, or voluntary disclosure: scovillesplice@gmail.com