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A Guide to ECCN Classification and Your Export Products

What is an ECCN and how do I determine if my export products will have one?

If you have ever been asked to supply your commodity’s ECCN, the requestor is looking for the Export Classification Control Number. ECCNs are used for export control purposes and help identify if an export license may be required. This is a five digit number, which can be found on the Commerce Control List (CCL).

Before diving into the CCL, you must first determine whether or not your product falls into any of the ten CCL categories. These CCL categories can be found on the Bureau of Industry and Security’s (BIS) website and are also shown below. If your product does fall into any of these categories or you think it potentially could, then you will need to continue the ECCN classification process. Additional instructions regarding this process can be found in the below section titled ‘ECCN Classification’.

CCL Categories for ECCN 500 resized.jpg

If your company’s determination is that the product does not fit into any of these ten categories and it falls under the jurisdiction of the U.S. Department of Commerce, then it will be designated as EAR99. Most low technology commercial items that export from the United States are designated as EAR99, which means they do not have an ECCN and in most cases will not require a license. Although as the shipper, before determining an export license is not required you should ask the following questions.

  • Is this commodity controlled by any other agencies besides the BIS? (Dept of State DDTC, Dept of Treasury OFAC, etc.)
  • Is the destination or end user on a sanctioned list?
  • Will the product have a specific end-use, subject to higher controls?

If the answer is yes to any of these questions, then an export license will likely still be required regardless of an EAR99 designation.

ECCN Classification

Now, continuing the ECCN Classification process. If you think your product may fall into one of the ten CCL categories, the BIS recommends three ways for determining your ECCN.

  1. Ask the Manufacturer - If they are a different company from your own
  2. Classify the ECCN on your own – Instructions can be found HERE
  3. Obtain an official classification from the BIS

The above list has been significantly stripped down. Complete information and instructions for this process can be found on the BIS’s website, at the above link. We also suggest if you are brand new to this process that you speak with the BIS’s Outreach and Educational Services Division at (202) 482-4811. Since this responsibility lies with the shipper, it is important to ensure that your company is properly classifying your products, accurately determining if they possess an ECCN (or designate as EAR99) and discerning if an export license is required. Any miss-classifications or improper determinations of the above items, could result in fines or penalties levied by the relevant Government Agencies.    

Lastly in relation to determining an accurate ECCN, we would like to send out a reminder regarding a recent Amendment issued by the BIS. This Amendment took effect on April 19, 2017 and is summarized below. 

82 FR 6216 – Support Document Requirements with Respect to Hong Kong

Effective April 19, 2017 this rule requires persons intending to export or re-export to Hong Kong any item subject to the Export Administration Regulations (EAR) and controlled on the Commerce Control List (CCL) for national security (NS), missile technology (MT), nuclear nonproliferation (NP column 1), or chemical and biological weapons (CB) reasons to obtain, prior to such export or re-export, a copy of a Hong Kong import license or a written statement from the Hong Kong government that such a license is not required. In addition, the rule also requires persons intending to re-export from Hong Kong any item subject to the EAR and controlled for NS, MT, NP column 1, or CB reasons to obtain a Hong Kong export license or a statement from the Hong Kong government that such a license is not required. 

For additional information, contact an Export Counselor at the BIS Directly. Complete contact information for the BIS can be found HERE and also below.

Ask an Export Counselor

Links to BIS East Region and West Region

To speak with an Export Counselor, you may call one of the following numbers:

(202) 482-4811 - Outreach and Educational Services Division (located in Washington, DC)
(949) 660–0144 - Western Regional Office (located in Newport Beach, CA)
(408) 998-8806 - Northern California branch (located in San Jose, CA)

You may also e-mail your inquiry to the Export Counseling Division of the Office of Exporter Services at: [email protected]

We hope you found this blog helpful! The information provided here is not legally binding for Vantec Hitachi Transport System (USA), Inc. and/or any government agencies. It is considered courtesy opinion only and does not absolve exporters of their responsibilities under Export Administration Regulations.

Check out our blog library to learn more about other import and export compliance topics.

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A Guide to ECCN Classification and Your Export Products

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