While assisting a client this week they made a common, but inaccurate, assumption that if their commodity is classified for export as EAR99 then NLR (No License Required) automatically applies. Not necessarily.
Here is some info from the BIS (Bureau of Industry and Security) website:
What does EAR99 mean?
If your item falls under U.S. Department of Commerce jurisdiction and is not listed on the CCL, it is designated as EAR99. EAR99 items generally consist of low-technology consumer goods and do not require a license in most situations. However, if your proposed export of an EAR99 item is to an embargoed country, to an end-user of concern, or in support of a prohibited end-use, you may be required to obtain a license.
Contact firstname.lastname@example.org for assistance