Commerce Control List Categories
Under the EAR, the list of items controlled is called the Commerce Control List (CCL). Exporters are required to navigate through this list to determine the correct Export Control Classification Number (or ECCN) for both their item and its associated technology.
ECCN is a five-character alphanumeric designation used in the CCL to classify exports and determine if additional export licenses are needed from the Department of Commerce. On the other hand, an ECCN categorizes exports based on commodity and respective technical parameters.
Here is a quick reference of the ten categories included in an ECCN:
- 0 = Nuclear materials, facilities, and equipment (and miscellaneous items)
- 1 = Materials, Chemicals, Microorganisms, and Toxins
- 2 = Materials Processing
- 3 = Electronics
- 4 = Computers
- 5 = Telecommunications and Information Security
- 6 = Sensors and Lasers
- 7 = Navigation and Avionics
- 8 = Marine
- 9 = Propulsion Systems, Space Vehicles, and Related Equipment
The CCN categorization system is broad, so your company needs to be careful when you determine how to report a specific ECCN. If your product falls under the jurisdiction of the Bureau of Industry and Security (BIS), then you could be subject to additional scrutiny outside of ITAR or EAR.
How To Determine Your ECCN
Talk To Your Manufacturer
ECCNs change over time, but you could talk to an item’s manufacturer to see the most recent ECCN. Make sure you review all agreements to understand export restrictions from the source that created products before exporting.
Self-Classify Your Products
Self-classifying an item is one of the best ways to ensure you comply with export controls based on product groups and other factors. However, you need to understand how the commerce control list is structured and formatted to classify an item against the CCL.
Once technical details are understood, you can match characteristics to the ECCN provided by the commerce control list.
Request From BIS
The third way exporters can identify the ECCN is to submit an official request to the BIS. To go this route, exporters need to submit their CIN to the official website, but this route can take a long time and limit six items.
Once an ECCN has been determined, exporters must cross-reference the country chart to determine if a license is required for export. At the same time, they should pay careful attention to any license exceptions or other conditions that may apply to their particular transaction.
This process can be a daunting task – even for those with years of trade compliance background.
What Other U.S. Export Control Classifications Should I Know About?
The Harmonized Tariff Schedule
The Harmonized Tariff Schedule of the United States (HTS) is a 10-digit code used by the U.S. government to classify imports. This code is controlled by the U.S. International Trade Commission (ITC) and must be used by U.S. importers.
Schedule B Numbers
The U.S. government pays careful attention to exports for national security and monetary reasons like tariffs. To help with the process, the U.S. government collects statistical information about exports with Schedule B codes. Schedule B codes are a subset of HTS codes, and they are typically more comfortable to use and faster to process than the standard HTS numbers.
HS codes are a set of six-digit codes used by countries around the world. This standardized code helps identify the duty and tax rates of product groups, software, and related technology. Your company will use HS codes when working with customers, vendors, and foreign nationals who reside outside the U.S.
Does Your Company Have The Right Classifications & Licenses?
U.S. export controls and licenses can be a challenge to understand and maintain. Classification requires an in-depth knowledge of your products and regulations to accurately choose a specific Export Control Classification Number and other considerations.
Export Solutions is a trusted partner with many businesses just like yours. Our export and import consultants have years of experience and knowledge that you need to handle the heavy lifting for all of your export control purposes.
Here are just a few ways that our team will help you secure your business and protect against unwanted fines and penalties:
- Our team can help you navigate EAR classification and licenses:
- We have years of experience determining the correct ECCN for practically every item on the CCL.
- We will evaluate any exceptions or other special conditions that may apply to your transaction.
- If needed, we can work with you to prepare and submit your export license application to the U.S. Bureau of Industry and Security (BIS)
- Once your license is approved and you’re ready to export, we can advise you on meeting any conditions/provisos of the license, including what to communicate to your end-user and how to prepare your shipping documentation before export.
Do you want to save time, money and avoid costly fines/penalties? Our team of trade compliance experts is standing by to help you free up your time and resources so you can focus on your business!