# Export Control Screening Checklist for Manufacturers > Source: https://netray.co/tools/export-control-screening-checklist > Publisher: Netray (netray.co), AI and integration engineering for ERP and manufacturing systems. > Section: Free Tools ## Short answer A 28-point checklist for screening every order, party, and shipment against EAR and ITAR requirements - restricted parties, classification, end-use, licensing, and documentation. ## Category aerospace-defense ## Tool **Kind:** checklist **Groups:** #### Restricted Party Screening **Items:** **Text:** All customers, ship-to parties, and end users are screened against U.S. government consolidated lists (Denied Persons, Entity List, SDN, Unverified, Debarred) **Critical:** true Suppliers, freight forwarders, banks, and other transaction parties are also screened, not just customers **Text:** Screening is automated or systematically performed at order entry and again before shipment **Critical:** true Fuzzy/name-variant matching is used, and potential matches are escalated to a trained reviewer rather than self-cleared Screening results (including negative results) are recorded and retained with the transaction Existing customers and open orders are rescreened when lists are updated #### Jurisdiction and Classification **Items:** **Text:** Every product, spare part, and item of technical data has a documented jurisdiction determination (ITAR/USML vs. EAR/CCL) **Critical:** true **Text:** EAR items have an assigned ECCN (or documented EAR99 rationale), reviewed when regulations change **Critical:** true Classifications are stored in the ERP item master so they follow the part through quoting, orders, and shipping New products and engineering changes trigger a classification review before first sale or transfer Customer-provided classifications are verified rather than accepted at face value Commodity jurisdiction or classification requests (CJ/CCATS) are filed where self-classification is uncertain #### End-Use and End-User Review **Items:** **Text:** Orders are reviewed for prohibited end uses (military, missile, nuclear, chemical/biological) where the EAR requires **Critical:** true **Text:** Red flags are checked: reluctance to state end use, mismatched product-to-business, unusual routing or payment, freight-forwarder-only addresses **Critical:** true End-user statements or certificates are obtained where required by license or policy Military end-use/end-user rules for China, Russia, and other designated countries are applied to affected transactions Transshipment and diversion risk is assessed for high-risk destinations and intermediaries A documented procedure exists to stop and escalate a transaction when red flags cannot be resolved #### License Determination and Management **Items:** **Text:** A documented process determines license requirements from classification + destination + end user + end use before commitment **Critical:** true License exceptions (EAR) and exemptions (ITAR) are applied only with documented eligibility analysis Licenses, agreements (TAA/MLA), and their provisos are tracked, with conditions communicated to affected teams License expiration dates and value/quantity limits are monitored before each shipment Deemed export licensing is considered when foreign person employees or visitors will access controlled technology #### Shipment Execution and Documentation **Items:** **Text:** Export clearance is a hard hold in the order-to-ship process - shipments cannot leave without compliance release **Critical:** true Electronic Export Information (EEI) is filed accurately in AES where required, with correct ECCN, license codes, and values Destination control statements appear on commercial invoices and shipping documents as required Hand-carried items, repairs/returns, and temporary exports follow the same screening and licensing process as standard shipments Export records - screening evidence, classifications, licenses, EEI, and shipping docs - are retained for at least 5 years **Scoring Note:** Screening failures are strict-liability events: shipping to a listed party or without a required license is a violation even if unintentional, with EAR penalties exceeding $300K per violation and ITAR penalties exceeding $1M. Every unchecked critical item is a live exposure in your current order flow - fix process holes before volume grows, because penalties scale per transaction. ## Content **Intro:** This free export control screening checklist gives manufacturers a transaction-level review of their EAR and ITAR screening process - the controls that must fire on every quote, order, and shipment. Twenty-eight checkpoints cover restricted party screening, jurisdiction and ECCN/USML classification, end-use and red-flag review, license determination, and shipment execution. It is designed for aerospace, defense, and electronics manufacturers whose products, spares, or technical data cross borders or reach foreign persons. Use it to audit your order-to-ship workflow end to end, because export violations are strict liability: intent does not matter, and a single missed screen can cost more than a year of profit on the account. **Sections:** #### Why screening must be systematic, not heroic **Body:** Most export violations at manufacturers are process failures, not rogue actors: an order entered under a slightly different customer name that screening missed, a spare part shipped under an expired license, an engineering change that shifted an item's classification with nobody noticing. That is why this checklist emphasizes systematization - screening embedded at order entry and pre-shipment, classifications stored in the ERP item master, and export clearance as a hard hold in the shipping process. A compliance program that depends on one experienced person remembering to check things fails exactly when volume rises or that person is on vacation, which is when penalties per-transaction stack up fastest. #### The screening benchmarks that matter **Body:** Calibrate your program against how enforcement agencies and well-run exporters actually operate: **Bullets:** - Screen at minimum twice per transaction - at order acceptance and again at shipment - because government lists change daily and weeks can pass between the two events - Screen all parties, not just the buyer: BIS enforcement actions regularly cite forwarders, intermediate consignees, and banks as the listed party - EAR civil penalties exceed $300K per violation or twice the transaction value; ITAR civil penalties exceed $1M per violation, and each shipment counts separately - Voluntary self-disclosure typically reduces penalties by half or more and is treated as a significant mitigating factor by both BIS and DDTC #### How to act on your gaps **Body:** Prioritize the critical items in workflow order. First, restricted party screening with rescreening on list updates - this is the cheapest control to automate and the most indefensible to lack. Second, classification completeness: an unclassified item cannot be correctly licensed or filed, so a classification backlog silently corrupts everything downstream, and the fix is a one-time classification project plus a trigger on new items and engineering changes. Third, the hard hold: verify that your ERP or WMS physically prevents shipment without compliance release, and test it by attempting to ship a flagged order. Finally, look backward - sample the last 12 months of exports against the checklist, and take anything questionable to export counsel to evaluate disclosure before an auditor or whistleblower finds it first. #### How Netray builds screening into your ERP **Body:** Export compliance lives or dies in the order-to-ship workflow, and that workflow lives in your ERP. Netray implements export control natively in Infor SyteLine, LN, and Baan: classification fields on the item master, automated restricted party screening integrated at order entry and shipping, license tracking with decrement-per-shipment logic, and hard compliance holds that make non-compliant shipment mechanically impossible rather than procedurally discouraged. Our on-prem AI can also pre-classify new items from drawings and descriptions for expert review and flag red-flag order patterns humans miss. If this checklist exposed process holes, we can close them inside the systems your team already uses. **Cta:** Audit your order-to-ship process against the checklist today, before your next shipment tests it for you. **Faq:** #### How often should restricted party screening be performed? **Answer:** At least twice per transaction - when the order is accepted and immediately before shipment - plus rescreening of your active customer and supplier base whenever government lists update, which happens continuously. Automated screening tools handle list updates and rescreening as a matter of course; manual programs almost never do. If you ship recurring orders to established customers, rescreening matters even more, because entities are added to lists while relationships are ongoing. #### What is the difference between an ECCN and a USML category? **Answer:** A USML category means your item is a defense article controlled by the State Department under ITAR - the strictest regime, requiring DDTC registration and licensing for virtually all exports. An ECCN is a Commerce Department classification under the EAR for dual-use and commercial items, where license requirements depend on the ECCN, destination, end user, and end use. Jurisdiction (ITAR vs. EAR) must be determined first; classifying an ITAR item under the EAR is itself a serious violation. #### Do export controls apply if I never ship outside the United States? **Answer:** Yes, in two important ways. Releasing controlled technology or technical data to a foreign person inside the U.S. is a deemed export, licensed as if you shipped to their home country - this covers foreign national employees, visitors, and even some cloud administration scenarios. Second, selling domestically to a customer you know or should know intends to export can create liability under the knowledge standards of the EAR. Domestic-only manufacturers with foreign staff or distributor customers still need a screening program. ## Search terms export control screening checklist, restricted party screening, denied party list screening, eccn classification checklist, ear itar screening process, export compliance checklist manufacturers, end use end user screening --- Talk to an engineer: https://netray.co/contact?intent=erp_ai | Machine catalog: https://netray.co/agent/catalog.json