One of the fields that the export trade community tends to have questions on is the Export Control Classification Number (ECCN) and how to know if their product has an ECCN. This blog seeks to provide an overview and resources available for these frequently asked questions.

An ECCN is an alphanumeric designation (i.e., 1A984 or 4A001) used in the Commerce Control List (CCL) to identify (for export control purposes) commercial or certain military items (i.e., commodities, technology and software) that have, or may have, military, terrorist or proliferation applications. The ECCN is based on the technical characteristics of the item and requires a detailed analysis of the item in order for it to be classified, and is not the same as a Schedule B number.

EAR99 is the designation for items that are subject to the Export Administration Regulations (EAR), but are not specifically listed in any of the CCL categories. Generally, EAR99 items may be shipped under the designation “NLR” which stands for “No License Required.” However, if your export of an EAR99 item is to an embargoed or sanctioned country, to an end-user of concern or in support of a prohibited end-use, you may be required to obtain an export license.

1.      Go to the source: Contact the manufacturer, producer or developer. Keep in mind that ECCNs may change over time, so you still need to review the ECCN to ensure its accuracy.

2.      Self-classify (Part 738): This will require a technical understanding of the item.  Additionally, you need to be familiar with the structure and format of the CCL.

For more information on the CCL structure, visit the BIS website.

3.      Official request to BIS: You may request an official classification from BIS after obtaining a Company Identification Number (CIN) and using the electronic application processing system, SNAP‑R.

Once you have classified the item, turn to the information below your ECCN entry on the CCL to determine whether a license is required. You do this by cross-referencing the “Reasons for Control” of the item and the country of ultimate destination in the “Commerce Country Chart” (Supp.1 to part 738). Some controls apply only to certain subparagraphs, so note carefully which apply to your item. Also, an item may have more than one control associated with it.

If there is an “X” in the intersection of the column based on the reason(s) for control of your item and the line for your destination in the “Commerce Country Chart” (Supp.1 to part 738), you have a licensing requirement, unless a license exception is available. If there is no “X” at the intersection of the control column(s) specified under your ECCN and your ultimate destination, you will not need an export license unless you are exporting to an end-user or end-use of concern or any other General Prohibition applies. For additional information on license exceptions (part 740), General Prohibitions (part 736), or end-users or end-uses of concern (part 744), refer to “Introduction to the Commerce Department’s Export Controls.”

Visit the BIS website for more information regarding SNAP-R and CINs.

For assistance with self-classification or submitting a request for classification, the Office of Exporter Services has counselors available in Washington, D.C., at 202-482-4811, and in the Western Regional Office in California at 949-660-0144 or 408-998-8806.