EAR ECCN Self-Classification Worksheet
Before you export, reexport or release technology to a foreign person, you need to know whether the item is controlled by the ITAR or the EAR, and if it is on the Commerce Control List, under which ECCN. This worksheet keeps that reasoning in one auditable place.
| Item / part number | Description | USML review result | CCL category | Product group | ECCN or EAR99 | Reasons for control | Evidence relied on | Reviewed on | Status | |
|---|---|---|---|---|---|---|---|---|---|---|
Classification is the exporter's responsibility. This worksheet records your reasoning; it is not a government determination. When in doubt, consult counsel or request a CCATS from BIS. Check the current Commerce Control List for exact entries before relying on any example ECCN shown here.
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How to use the worksheet
Add one row per part, assembly, software build or technology package. First record the USML review result, because ITAR jurisdiction comes before EAR classification. If the item is not on the USML, move to the Commerce Control List: choose the category 0 to 9, the product group A to E, and then the ECCN, or EAR99 when nothing matches. Capture the reasons for control and the evidence you used so a colleague can reproduce your decision later.
The order of review
The EAR has an order of review that starts with confirming the item is subject to the EAR and not the ITAR, then walks the CCL from category to ECCN, and finally checks parameters in the entry. An ECCN is a five-character code: category digit, product group letter, then three digits that indicate the type of control. Reasons for control such as national security or regional stability then drive licence requirements by destination.
- Jurisdiction first: ITAR USML or EAR.
- Then category, product group and ECCN.
- Then reasons for control and licence exception eligibility.
Keeping classifications usable
A classification only helps if it reaches the people who ship. Tie each decision to the item master in your ERP and review it when a design, firmware version or supplier changes, since a modified part can classify differently. Record who approved the decision and when. Mark rows that are drafts so nobody ships against a guess.
Common mistakes
Frequent errors include classifying by the supplier's catalog label instead of the actual parameters, skipping the USML check for specially designed items, forgetting that software and technology carry their own ECCNs, and treating EAR99 as a default rather than a conclusion reached after review. Also remember that end use, end user and destination can create licence requirements even for EAR99 items.
Frequently Asked Questions
What is an ECCN?
An Export Control Classification Number is the code for an item on the Commerce Control List under the EAR. It has a category digit, a product group letter and three further digits. It determines which licence requirements apply by destination and end use.
Can I classify my own products?
Yes. Exporters are generally responsible for self-classifying under the EAR. If you are unsure, you can ask BIS for a formal classification through a CCATS request, or use the commodity jurisdiction process with the State Department when ITAR coverage is uncertain.
What does EAR99 mean?
EAR99 is the designation for items subject to the EAR that are not listed on the Commerce Control List. Most EAR99 items can ship without a licence to most destinations, but sanctions, embargoes and prohibited end users or end uses can still require authorisation.
How often should I review classifications?
Review when the item design changes, when a new firmware or software release adds capability, when the CCL or USML is amended, and on a regular schedule such as annually. Keep the date and reviewer on each record.
If classification data lives in spreadsheets today, Netray can help connect it to your item master and shipping holds in an on-prem setup.
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