In previous posts I have noted that many clients automatically enter EAR 99 and NLR when submitting EEI (Electronic Export Information) filings.
EAR 99 commodities fall under US Department of Commerce jurisdiction but are not listed on the CCL (Commerce Control List). NLR indicates No License Required.
Compliance best practices include at least annual verification of classifications. The CCL Index has been updated effective 05/20/2021. The list is alphabetical and easy to check so you may find that you should be using an ECCN (Export Control Classification Number) instead of EAR 99. Here is the link to the CCL Index:
Contact firstname.lastname@example.org for help with export compliance.