A Little Due Diligence

As I have written in previous posts, it is a mistake to leave export compliance in the hands of your shipping department. Shippers are under time pressure to get shipments out the door and often do not have sufficient knowledge or training to avoid mistakes. In addition shippers rarely have the authority to stop shipments if they spot red flags and this can have big consequences. So don’t give shippers the responsibility for compliance without the authority.

Many exporters automatically classify their shipments as EAR99 and NLR without checking that these designations are accurate. A little due diligence goes a long way so here goes.

Exporters, do you know how to determine your ECCN (Export Control Classification Number)? While it is true that many exported commodities can be designated EAR 99 and NLR (No License Required), it is important to first check for an ECCN. The correct ECCN is necessary in order to determine if a license is required for your shipments.

There are three ways to determine ECCN: 1) self classify, 2) consult manufacturers of commodities, 3) request a classification by BIS.

The CCL (Commerce Control List) Index @ bis.gov is a good place to start.


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