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Screening sample shipments is easy to forget. A sample or demo unit feels low risk. It has little value. Nobody is paying for it. So teams ship it fast and skip the checks they run on paid orders. That gap is where trouble starts. The rules on denied party screening do not care about the invoice value. They care who receives the goods.
A free sample to a blocked party is still a violation. A demo unit loaned to a listed distributor is still a violation. This guide shows how to screen samples and demos the right way. It covers valuation, licensing, trade shows, loaned units, and the parties you must check every time.
Why samples and demos get missed
Sample shipments move outside the normal order flow. A salesperson sends a unit from a trade show. Marketing mails product to a reviewer. An engineer ships a demo to a prospect. These often skip the order system that triggers your screening. No purchase order means no automatic check.
The value on the invoice adds to the confusion. A sample marked “no commercial value” looks harmless. But screening has nothing to do with price. It is about the person or company on the other end. If they sit on a restricted list, the shipment breaks the law regardless of cost. If you are unsure who must screen, read who needs to do denied party screening.
Screening applies to every shipment, paid or not
US export rules restrict who you can deal with. That covers gifts, samples, demos, and loans. A shipment with a zero-dollar sale value is still an export. It still needs the same party checks as a paid order. For the basics, see denied party screening 101.
You screen against government lists from three main agencies. The Treasury runs sanctions and the SDN list. Commerce runs the Entity List and Denied Persons List. State runs its own debarred list. Many of these feed the free Consolidated Screening List from the US government. Your consolidated screening list guide explains what it does and does not include.
Parties you must check on a sample shipment
- The person or company receiving the sample
- The end user, if different from the receiver
- Any distributor or agent handling the demo
- The freight forwarder and any intermediate consignee
- The individual at a trade show booth who takes the unit
Check ownership too. The 50 percent rule blocks entities owned half or more by a listed party, even when that entity is not named. See the 50 percent rule in sanctions screening.
Value does not remove the license question
A low value does not waive a license. Whether a sample needs an export license depends on the item, the destination, and the end user. It does not depend on price. A controlled item worth ten dollars can still require a license. A demo of sensitive technology can still be restricted. Confirm the classification before you ship. Our guide on do I need an export license walks through the steps.
Many low-risk products fall under EAR99 and ship without a license to most destinations. But EAR99 is not a free pass. You still cannot send an EAR99 sample to a denied party or an embargoed country. Read EAR99 basics for the detail.
Valuing a sample correctly
You still declare a value for customs, even on a free sample. Use a real figure. Do not enter a random one dollar or five dollars to move it faster. Customs can challenge an amount you cannot back up. The exporter carries that responsibility, not the buyer.
Use a commercial invoice, not a proforma one. Mark the goods clearly so customs understands the shipment is not a sale.
| Sample type | Suggested marking | Value column |
|---|---|---|
| True sample, cannot be used or resold | “Sample, no commercial value. Value for customs purposes only.” | Real customs value, 0 in the billing column |
| Working unit that could be used or sold | “Sample, no charge. Value for customs purposes only.” | Real customs value, 0 in the billing column |
Demos, loans, and temporary exports
Demo units often go out and come back. That is a temporary export. It still needs screening and a license check on the way out. The return does not erase the original export.
ATA Carnets
An ATA Carnet lets you move demo goods across borders without paying duty each time. It suits sales teams touring several countries with the same units. The carnet handles customs. It does not handle screening. You still check every party and destination before the trip.
Loaned demo units
A unit loaned to a prospect is an export to that prospect. Screen the borrower before it leaves. If the prospect later fails a screen, you have a problem you could have caught early. Keep the loan on record with the screening result.
Trade shows and hand-carried samples
Trade shows create the highest risk. Staff give out units on the spot. A prospect walks up and takes a demo. Nobody screens the receiver. That is an export with no check behind it.
Hand-carrying a demo in your luggage is also an export. The rules apply the same way as a freight shipment. Set a booth rule that no controlled item leaves without a name and a screen. For a wider view, read denied party best practices.
Watch for deemed exports at demos
Showing controlled technology to a foreign national can be a deemed export, even inside your own country. A live demo of sensitive tech to a foreign visitor may need authorization. See deemed export for how this works.
Red flags on sample and demo requests
- A request for many free samples with no clear business reason
- Shipping to a freight forwarder address with no named end user
- A buyer who refuses to say how the demo will be used
- A demo request routed through a third country near an embargoed one
- Contact details that do not match the company name
These patterns can signal diversion. Learn more in red flags of sanctions evasion.
Build screening into the sample process
The fix is to make screening a required step before any sample or demo leaves. Do not rely on memory. Wire the check into the request, so no unit ships without it.
- Route every sample and demo request through one intake form
- Screen the receiver, end user, and forwarder before dispatch
- Confirm the item classification and any license need
- Set a trade show rule that ties every giveaway to a screen
- Save the screening result with the shipment record
Keep records of each screen. Save the date, the list version, and the result. Regulators expect proof, and samples are no exception. See record keeping for denied party screening. A simple denied party screening checklist helps your team apply the same steps every time.
Frequently Asked Questions
Do I need to screen a free sample?
Yes. Screening is about the party, not the price. A free sample to a denied party is still a violation. Run the same checks you run on a paid order.
Does a low-value sample ever need an export license?
It can. The license question turns on the item, the destination, and the end user. Value does not remove it. A controlled item worth a few dollars can still require a license.
Is handing a demo to someone at a trade show an export?
Yes. Giving a unit to a foreign party is an export, even in person. Screen the receiver before the unit changes hands. Hand-carried demos count the same way.
What value do I put on a sample invoice?
Use a real value for customs and mark the goods as a sample not for sale. Do not enter a random low figure you cannot support. The exporter is responsible for accuracy.
Key Takeaways
Samples and demos carry the same screening duty as paid orders. Value never removes the need to check the party or the license. Screen every receiver, end user, and forwarder before a unit leaves, and treat trade shows and loaned demos as real exports. Build the check into your sample process, keep the records, and no free unit will turn into a penalty. If you want help setting this up, contact us.