I frequently conduct no fee discussions (phone or Zoom) with new clients to determine if I can help them. They may be unsure about their HTS codes or a specific regulation. Exporters quite often assure me that their commodities fall under EAR 99 and NLR (No License Required). While this may be true, due diligence requires verification which starts with checking ECCN (Export Control Classification Number). BIS (Bureau of Industry and Security) spells out the specific procedures for checking ECCN and licensing requirements. The CCL (Commerce Control List) Index is a good place to start.
Here is some more info from the BIS 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.
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