EAR 99 and ECCN Re-Visited

From the archives…Many exporters automatically enter EAR 99 on their shipping documents without really knowing what this designation means. EAR 99 is a basket category for items that are subject to the EAR (Export Administration Regulations) but not on the CCL (Commerce Control List).  The CCL lists “controlled” items which may require a license for export. The CCL is made up of a classification of items by ECCN (Export Control Classification Number).  So a basic export compliance step is to verify if your items are “controlled” needing an ECCN or if they can be shipped under EAR 99. If an ECCN is listed you then need to determine if a license is required by checking “Reasons for Control” and destination country lists. There are 3 ways to determine an ECCN: 1) Check with the manufacturer, producer, or developer. 2) Self classify using the CCL. 3) Official request to BIS (Bureau of Industry and Security) using the SNAP-R tool @ bis.gov   Contact mitch@adhoclogistics.com for help in determining your ECCN.