Export Control Classification Numbers

When exporting a commercial article, software or technology abroad that is of “dual use,” i.e., that has both civilian and military or proliferation applications, the Bureau of Industry and Security (BIS) within the US Dept. of Commerce, has control over these exports through the Export Administration Regulations (EAR).  BIS actually has control over most commercial articles exported, however, other agencies such as the Dept. of State, control certain specific exports and their requisite licenses, such as defense articles and defense services.

A relatively small percentage of total U.S. exports and reexports require a license from BIS. License requirements are dependent upon an item's technical characteristics, the destination, the end-user, and the end-use. You, as the exporter, must determine whether your export requires a license. When making that determination consider:

• What are you exporting?
• Where are you exporting?
• Who will receive your item?
• What will your item be used for?

-- BIS Introduction to Commerce Dept. Export Controls

The Commerce Control List (CCL) lists Export Control Classification Numbers (EECN), which categorizes articles based on the nature of the product type and its respective technical parameters. An EECN is an alphanumeric designation, e.g., 5A004, used to identify items for export control purposes.

There are 3 approaches to figuring out an ECCN:

1.    Ask the manufacturer, producer or developer if they have a current ECCN for the item.

2.    Self-classify the item, which would require a familiarity with the format and structure of the CCL, not to mention a technical understanding of the item.
3.    Make an official request to BIS for a classification.  This is done using the BIS electronic licensing system known as “SNAP-R.”

   In order to use this, both a Personal Identification Number and a Company Identification Number must be obtained from the BIS website.

Once the ECCN has been determined, you can identify which transactions may require an export license based on reasons such as the country of destination, any exceptions to obtaining a license which may apply, and why control is exercised over the item.

While BIS is unable to provide a definitive commodity classification over the phone through its Office of Exporter Services, BIS counselors are available to advise exporters on making ECCN determinations using online resources. Call the BIS Help Desk at (202) 482-4811.

For formal requests made through SNAP-R, technical staff at BIS will review submissions and provide an official classification within 4 to 6 weeks.

Questions or comments? Feel free to contact me at clark.deanna@gmail.com