Process & Policies

For U Faculty & Staff

Policies that must be taken into consideration when performing various purchasing activities:


The University is committed to providing equitable access to information technology and all departments are responsible for implementing the University accessibility requirements. Purchasing hardware and software products or web site design services, are some examples of where you may need to work with the Accessibility Department to ensure your purchases are compliant.

Gramm-Leach-Bliley Act

The Gramm-Leach-Bliley Act (GLBA) requires the University of Minnesota to implement safeguards to insure the security and confidentiality of certain non-public customer information. This imposes on the University the obligation to select only suppliers that can demonstrate their ability to safeguard non-public financial information to which suppliers might have access, or be granted access by the University

If you are drafting a Request for Proposal (RFP) and it deals with any of the financial services/products that may apply to GLBA and the supplier may have access, or be granted access by the University to non-public customer information identifiable to an individual (student, employee, customer, etc.) additional questions may need to be included.

Gramm-Leach-Bliley Act

Health Information Portability and Accountability Act (HIPAA)

The Health Information Portability and Accountability Act (HIPAA) is designed to protect an individual's personal health information (referred to as PHI) and to restrict how PHI may be used. If you are purchasing something that may involve PHI you may need to discuss this further with the Health Information Privacy & Compliance Officer and may need to include additional questions if drafting a Request for Proposal (RFP).

Health Insurance Portability & Accountability (HIPAA)

Payment Card Industry Data Security Standards (PCI DSS)

University colleges and business units that accept credit cards as payment for goods and services are obligated to follow the Payment Card Industry Security Standards (PCI DSS). These standards protect cardholder data.

If you are purchasing any solution that involves payment cards (even if your department is not accepting those cards) additional security related questions may need to be included in Request for Proposal (RFP) along with the University's Cardholder Data Security document. The University's PCI Compliance Officer may also need to be included in these discussions.

Payment Cards/PCI DSS Standards Compliance

Sarbanes-Oxley Act (SOX)

The Sarbanes-Oxley Act (SOX) was enacted November 15, 2004 and is intended to deter abuses by accounting professionals. The law now requires accountants to prepare corporate financial reports in accordance with generally accepted accounting principles (GAAP), the commonly accepted standard of recording and reporting accounting data.

All University purchases for auditing or financial services must be conducted with suppliers who are compliant with SOX and its requirements.

Contact if you have questions about a specific purchase that may be covered by SOX.

The Office of Institutional Compliance administers the University's individual and institutional conflict of interest review processes.

Conflict of Interest Policy

The University Conflict of Interest requirements are governed by Minnesota Statute MS15.43.


Subdivision 1. Financial Interest agents. No employee of the state or University of Minnesota in direct contact with suppliers or potential suppliers to the state or the university, or who may directly or indirectly influence a purchasing decision or contract by establishing specifications, testing purchased products, evaluating contracted services, or otherwise has official involvement in the purchase or contracting process may:

  1. Have any financial interest or have any personal beneficial interest directly or indirectly in contracts or purchase orders for goods or services used by, or purchased for sale or furnished to a department or agency of the state or the university; or
  2. Accept directly or indirectly from a person, firm, or corporation to which a contract or purchase order has been or may be awarded, a rebate, gift, money, or anything of value other than items of nominal value. No such employee may further accept any promise, obligation or contract for future reward...

    (Re: Subdivision 4. Penalties. A violation of this section is a misdemeanor.)

It is also the policy of the Purchasing Department to comply with the Anti-Kickback Act of 1986 which provides that no fees, gifts, gratuities, or compensation of any kind may be offered or accepted for the purpose of obtaining favorable treatment in the acquisitions of goods or services with federal funds. Possible violations of the Anti-Kickback Act of 1986 should be reported to the University of Minnesota, Director of Audits, (612) 625-1368.

Purchasing Services recommends that you use the University's contract customs broker, DB Schenker (U-Wide Agreement #U225.1). A fee is required for their service, but their expertise can save an inexperienced importer both time and money in the long run.

Our representative at DB Schenker is Charlie Christ at (651) 367-8810 or email at

To ensure the smoothest process possible for any Department Purchase Orders issued to Foreign Suppliers, the following procedure is suggested:

In the text portion of your Purchase Order (PO), insert the following statement:

"When equipment is ready to ship, please contact our Import/Export Broker at (651)367-8810 or email at"

For more information, contact DB Schenker Minneapolis:
Phone: (651) 367-2500

Exporting Goods and Services

When exporting equipment or goods, the following are items of discussion you will need to have with the supplier and/or export broker (DB Schenker):

  • Commercial invoice
  • Shipper's letter of instructions (SLI)
  • Inco terms
  • Value - the actual value to be reported to customs
  • Commodity
  • Harmonized codes (classification number for goods)
  • Dangerous goods
  • Reserach equipment
  • Temporary exports/goods being returned
  • Purchase Order number or Billing Number

Agent for Customs Clearance

The University of Minnesota has one main agent for customs clearance; Schenker International Forwarders. Generally speaking, Schenker International will handle large bulky shipments valued at over $1,250. Schenker can and will handle smaller shipments as well. Below is more detail information about Schenker International.

Contract Information

DB Schenker International
860 Blue Gentian Road, Suite 245
Eagan, MN 55121
Phone: (651) 367-8810
Fax: (651) 367-8811

Services Provided

International Ocean Freight Forwarding
Export and import; consolidated or full containers; full or partial charters; roll on/roll off, barge and pontoon.

International Air Freight Forwarding
Export and import; direct flights with reserved cargo capacity; regular consolidated air cargo departures; full charter for special projects.

Customhouse Brokerage Operations
Licensed brokers in each USA office; ABI customs interface; formal/informal entries; dutiable/duty free/GPS entries; general term bond and term bond application; duty drawback.

Project service, logistics planning, warehousing and distribution
Export and import documentation, tracking, tracing and status reports, packing, staging and distribution, cargo insurance.

Import by Air Freight

All merchandise purchased from outside the United States is inspected by United States Customs officials upon its entry into the country. U.S. Customs procedures help assure that imports are processed as quickly and as accurately as possible. They also help protect American business in international trade.

What does Customs do?
The primary duties of U.S. Customs include the assessment and collection of all duties, taxes, and fees on imported merchandise, supervision of entry and unloading of vessels, and enforcement of customs laws. They also work to combat smuggling and fraud on customs revenue and enforce the regulations of several other Federal agencies at ports of entry in the United States.

Entry Process
When a shipment reaches the United States, the importer (specifically, purchaser, or licensed customs broker designated by the purchaser) must file entry documents with U.S. Customs officials for their merchandise at the port of entry, usually Minneapolis-St. Paul or Chicago. Imported goods are not legally entered until after the shipment has arrived within the port of entry, goods have been examined by customs, delivery of the merchandise has been authorized by customs, and estimated duties have been paid.

Duty-Free Entry
The U.S. Custom's regulations provide that scientific and apparatus intended exclusively for educational purposes or pure scientific research used by qualified non-profit institutions shall enjoy duty-free entry if instruments or apparatus of equivalent scientific value are not being manufactured in the country of importation.

You must make application for Duty-Free Status and your application must be approved by the Department of Commerce for the Duty-Free Status to be effective. You must make application yourself, the University of Minnesota's Import/Export Broker cannot perform this task for you.

U.S. Custom's regulations state that an applicant for duty-free entry for an instrument must be a public or private non-profit institution which is established for educational or scientific purposes and which has placed a bona fide order or has a firm intention to place a bona fide order for a foreign instrument within 60 days following a favorable decision on the institution's application.

Applications must be made on form ITA-338P. Five copies of the application form must be submitted, one of which must be signed in the original by the person in the applicant institution under whose direction and control the foreign instrument will be used and who is familiar with the intended uses of the instrument.

Form ITA-338P (pdf)

Form ITA 338P Detailed Instructions

If you need other assistance with this form, contact Jan Kopczeski at (612) 624-1696.

Who Imports Goods?
Merchandise arriving in the United States by commercial carrier must be entered by the purchaser or by the licensed customs broker designated by the purchaser.

Customs brokers (Schenker or otherwise designated) are authorized by the tariff laws of the United States to act as agents for importers in the transaction of their Customs business (the U of M is the importer). They are private individuals or firms licensed by the Customs Service. Customs brokers represent their clients in customs matters which include but are not limited to document preparation and delivery of goods from airport to the end-user. The fees charged for customs broker services may vary according to the extent of services performed.

  • The importers or Licensed Customs Brokers for the University is Schenker International unless the selling supplier has designated their own importer as part of the purchase.
  • U.S. Customs employees are not authorized to act as agents for importers.

Import by Ocean Freight

As the owner of the goods, the department may enter merchandise through U.S. Customs. For a complete list of all customs requirements visit the U.S. Bureau of Customs and Border Protection homepage.

On January 26, 2009, the new rule titled Importer Security Filing and Additional Carrier Requirements (commonly known as "10+2" or "ISF") went into effect. The new rule applies to import cargo arriving to the United States by ocean vessel. Failure to comply with the new rule could result in substantial fines, increased inspections and delay of cargo.

ISF importers, or their agent (the agent for the University is DB Schenker), must provide the following data, no later than 24 hours before the cargo is laden aboard a vessel destined to the United States. Data must include:

  • Seller
  • Buyer (The "Legal" name of the University is "Regents of the University of Minnesota")
  • Importer of record number/FTZ applicant identification number (Tax ID Number)
  • Consignee number(s) (Tax ID number filled out)
  • Manufacturer (or supplier)
  • Ship to Party (Regents of the University of Minnesota)
  • Country of Origin (Regents of the University of Minnesota, Department Name)
  • Commodity Harmonized Tariff Schedule of the United States (HTSUS number)
  • Container stuffing location
  • Consolidator

There are two data sets that are required from carriers:

  • Vessel stow plan (includes vessel name, operator, container position, stow position, etc.)
  • Container status messages for all of the events of that shipment (AMS Bill of Lading)

Job Aids

Customs Terminology | pdf |

DB Schenker INCO Grid | pdf |

Understanding FOB Terms | xlsx |

Minnesota Statutes, Session Laws, and Rules

Compiled by the Office of Revisor of Statutes. The most current compilation of Minnesota Statutes and Minnesota Rules can be found on the site listed below.

Link to Minnesota Statutes, Laws, and Regulations

Uniform Guidance

The Office of Management and Budget (OMB) has combined many federal circulars,including A21 and A110, into a single guidance document that can be used by all agencies. This combined document is know as "Uniform Guidance."

Read the full Uniform Guidance: 2 CFR 200. Uniform Guidance (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards)

Federal Contracts

Additional Terms & Conditions (Flowdowns) for Federal Contracts (pdf)

Cert:Certificate of Compliance with Federal Requirements - Payments to Influence, Debarment, Clean Air & Water (Required for purchases $150,000 and over funded by a federal contract)

Tax Certificate of Exemption and W-9 Tax ID

The University of Minnesota is exempt from MOST, not all, Minnesota Sales Tax. Please read the following for more information on State Tax Exemption laws.

Click on the appropriate link below to access the proper form/document.