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If you ship a commercial item from the United States to a foreign 

destination, your transaction is likely to be subject to the jurisdiction 

of the U.S. Department of Commerce. The Bureau of Industry 

and Security (BIS) within the U.S. Department of Commerce 

has jurisdiction over the export and reexport of “dual-use” items 

(i.e., commodities, technology and software that have both civilian 

and military or proliferation applications). These controls are 

implemented through the Export Administration Regulations (EAR).

If your item is subject to the jurisdiction of the U.S. Department 

of Commerce, you should first determine if your item is designated 

by an Export Control Classification Number (ECCN) on the 

Commerce Control List (CCL). The ECCN is a key factor in 

determining whether you need a license to export dual-use items 

outside of the U.S.

The Commerce Control List can be found in Supplement 1 to Part 

774 of 15 CFR or at http://www.bis.doc.gov. Click the link for the 

“Commerce Control List” on the left side of the page.
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What is an ECCN?

An Export Control Classification Number (ECCN) is an 

alphanumeric designation (i.e., 1A984 or 4A001) used in the CCL 

to identify items for export control purposes. An ECCN categorizes 

items based on the nature of the product, i.e. type of commodity, 

technology or software and its respective technical parameters.

Once the ECCN has been identified, you can determine the reasons 

for control of the item, which transactions may require an export 

license based on the country of destination, and which license 

exceptions, if any, may apply.

What is an EAR99 designation?

Items that are subject to the jurisdiction of the EAR but are not 

on the CCL, are designated EAR99. EAR99 serves as a “basket” 

category for all such items.
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Determining Your ECCN:

There are three approaches to determine an ECCN:

1. Go to the Source: Contact the manufacturer, producer or 

developer to see if they have a current ECCN for the item. Keep in 

mind that ECCNs may change over time, so you still need to review 

the ECCN to be sure you are in agreement.

2. Self-Classify: In order to self-classify your item, you need a 

technical understanding of the item. Additionally, you need to be 

familiar with the structure and format of the CCL.

To classify your item against the CCL, begin with a review of the 

general characteristics of your item. The CCL is divided into ten 

categories. The first digit of the ECCN represents the category (see 

exhibit A). Each of the ten categories is divided into five product 

groups, represented by the second digit of the ECCN (see exhibit B). 

Once the appropriate category and product group are identified, 
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Commerce Control List Categories

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

Product Groups

A. Systems, Equipment and 

Components

B. Test, Inspection and 

Production Equipment

C. Material

D. Software

E. Technology

(Exhibit A) (Exhibit B)

match the particular characteristics and functions of your item to one 

of the specific ECCNs that follow. If the ECCN contains a list under 

the “Items” heading, you should review the list to determine within 

which subparagraph(s) your item is identified.

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If your item does not have a specific ECCN in any category of the 

CCL, then your item is designated as EAR99.

3. Official Request to BIS: You may request an official classification 

from BIS using the electronic licensing system, SNAP-R. You must 

obtain a Personal Identification Number (PIN) and Company 

Identification Number (CIN) to access the online system. For 

further information regarding SNAP-R and PINs, visit our website at 

http://www.bis.doc.gov/snap/pinsnapr.htm.

Once you have determined your ECCN: Next Steps

Once you have classified the item, the next step is to determine 

whether you need an export license. You do this by cross-referencing 

the “Reasons for Control” of the item and the country of ultimate 

destination. Here’s how:

Below the main heading for your ECCN entry, you will find 

“Reasons for Control” (e.g., NS for National Security, AT for AntiTerrorism, CC for Crime Control, etc.) and a “Country Chart” 
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reference associated with your item (e.g., NP Column 1). Some 

controls apply only to certain sub-paragraphs, so note carefully which 

apply to your item. Also, an item may have more than one control 

associated with it. Next, turn to the “Commerce Country Chart” 

(Supp.1 to Part 738). This is also available on our website.

If there is an “X” in the column based on the reason(s) for control of 

your item and the country of destination, a license is required, unless 

a License Exception is available. If there is no “X” in the control 

column(s) specified under your ECCN and country of 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, General 

Prohibitions, or End-Users of concern, refer to “Introduction to the 

Commerce Department’s Export Controls.”
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Frequently Asked Questions:

Does the Department of Commerce have jurisdiction over all 

exports?

The Department of Commerce does not regulate all goods, services, 

and technologies. Other U.S. Government agencies have export 

control responsibilities for regulating more specialized exports. For 

example, if you are shipping military goods, your item may be subject 

to the licensing jurisdiction of the Directorate of Defense Trade 

Controls at the Department of State. The BIS website identifies 

resource links for various U.S. Government agencies with export 

control responsibilities. See http://www.bis.doc.gov/About/reslinks.htm.

If my item is EAR99, does that mean I do not need a license?

It depends on all the facts of the transaction. 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 
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support of a prohibited end-use, you may be required to obtain an 

export license.

Are ECCNs and Schedule B numbers different?

Yes, an ECCN is different from a Schedule B number. A Schedule 

B number is used by the Census Bureau to collect trade statistics. 

There is no correlation between these numbering systems. Knowing 

a Schedule B number will not help to determine the ECCN. The 

Bureau of Census’s Foreign Trade Division can assist you with 

Schedule B numbers at 1-800-549-0595. A Schedule B search 

engine is available at http://www.census.gov/foreign-trade/schedules/b/. 

An ECCN is also different from the Harmonized Tariff System 

Nomenclature, which is used to determine import duties.

I have been told that I can get an official ECCN determination 

over the telephone from the Department of Commerce. Is this true?

No. The ECCN is based on the technical characteristics of the 

item and requires a detailed analysis of the item in order for it to 
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be classified. The Department of Commerce cannot provide you 

with an ECCN over the telephone. However, we can assist you 

in understanding how to do a self-classification of the item using 

on-line resources and your technical understanding of the item. We 

can also explain the process of submitting an official request for a 

classification. The Office of Exporter Services has counselors available 

in Washington DC at (202) 482-4811 and in our Western Regional 

Office in California at (949) 660-0144 or (408) 998-8806.

I have found an official classification done by the Department of 

Commerce back in 1996. Can I still use this? 

The Commerce Control List and ECCNs can change - sometimes 

items are added to the CCL and other times item specifications are 

changed or removed. In addition, your item may have different 

technical characteristics than what was classified previously. It is 

important to stay up-to-date with changes to the Commerce Control 

List which may affect your item’s classification.
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Need Further Assistance?

www.bis.doc.gov

Office of Exporter Services (OExS)

Outreach and Educational Services Divsion

Room 1099D

14th Street & Pennsylvania Avenue, N.W.

Washington, DC 20230

Office: (202) 482-4811

Fax: (202) 482-2927

OExS Western Regional Office

3300 Irvine Avenue

Suite 345

Newport Beach, CA 92660 

Office: (949) 660-0144

Fax: (949) 660-9347

160 W. Santa Clara Street

Suite 725

San Jose, CA 95113

Office: (408) 998-8806 

Fax: (408) 998-8677
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Instructions for Submitting a Commodity Classification Request to BIS

using the Simplified Network Application Process – Redesign (SNAP – R)

To submit a License Application or Commodity Classification Request on-line,

you first have to obtain a Company Identification Number (CIN) and Personal

Identification Number (PIN) number.

1) For PIN application go to: http:/www.bis.doc.gov/SNAP/pinsnapr.htm

2) Cut and paste the “Company PIN Certification letter” on your letterhead,

fill out and fax to 202-219-9182.

3) You will receive a call in about two weeks with your CIN and PIN.

4) Once you receive your PIN, you can submit the License Application (or

Commodity Classification Request) online at https://snapr.bis.doc.gov/

Be sure to go to the First Time User login.

5) You will then create a License Application or Commodity Classification Work

Item to submit.

6) Be sure to read the instructions in the SNAP-R User Manual before you begin

as it will answer all of your questions regarding how to fill out the form, at

www.bis.doc.gov/snapr/snapr_exporter_user_manual.pdf.
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NOTES