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Australian Export Controls and the Life Sciences

A guide to understanding export control laws regarding the physical export, intangible supply, publication or brokering of life sciences related goods, software or technology

9: Record-keeping requirements and reporting

The DTC Act requires a permit holder to keep records of the activities that are conducted under the permit for 5 years. There are various approaches that a permit holder can take to meet their obligation to keep a record of a supply, and these include:

  • keeping copies of the supply activity, e.g. saving the email which contains the permit number along with the details of the technology and recipient;
  • maintaining a register/log of supply activities, e.g. a spreadsheet with columns for the permit number, software or technology description, end-user/recipient, date supply commenced, and date supply ceased; or
  • making a note when the first supply activity occurs and a similar note when the supply activity concludes, or the permit expires.

Similar obligations to keep records of exported goods apply to permits issued under the Customs Act. In these circumstances, the obligation can be met by options including keeping a record of the commercial documentation that is generated to send the goods by sea, air or post.

Some permits have a condition that requires the permit holder to submit a report to us on the activities that occurred during a particular period. This condition will be clearly stated on the permit when it is issued. We will send you reminders when a report is due, and reminders if you do not submit your report in the required timeframe.

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