Compliance & ContractsFree worksheetPDF, Excel, Word exportDefense ContractingUnited States

Export Classification Matrix Worksheet

Classification is the first step of export compliance: until you know whether an item is ITAR, EAR or EAR99, you cannot pick a license, screen a customer or label an ERP record. This worksheet is a clean register to keep that decision and its basis in one place.

Download:
Part numberDescriptionJurisdictionUSML category or ECCNBasisReviewed byReview dateNext reviewAnnual units shippedUnit valueAnnual export value
$328,000
$148,800
$57,000
$375,000
Total annual export value
$908,800
Parts classified
4
Average value per part
$227,200

Control numbers in example rows are intentionally left as placeholders. Do not copy them; determine each item against the USML (22 CFR 121) or the Commerce Control List using a documented process. A pending status is a valid state, but pending items should be treated as controlled until resolved.

Push classifications into your ERP

Optional discussion of item master flags and shipment holds based on this register.

Optional. The tool and every export work without this. No spam.

How to use the matrix

List each part number or product family, choose the jurisdiction, record the control number and the basis for the decision, and add the reviewer and dates. Start with the items you actually ship abroad or share with foreign persons, then work through the rest of the catalog. Export to Excel and import the result into the ERP item master for flags and hold rules.

  • Jurisdiction first, then category or ECCN
  • Write down why, not just what
  • Set a next-review date on every row
  • Treat pending items as controlled

Order of review

A common approach is to check the USML first to see whether the item is specifically enumerated for a defense article. If it is not, move to the Commerce Control List and walk its Order of Review. If nothing fits, the item is EAR99. When jurisdiction is unclear, a commodity jurisdiction request to the State Department settles it, and BIS can issue a classification request response for CCL items.

Using the value column

The computed annual export value helps you rank review work. High-value, high-volume items deserve the first and deepest review, and the total shows how much of your revenue depends on the classifications being right.

Common mistakes

Relying on a supplier's classification without checking it, classifying by the part name instead of its technical parameters, and never revisiting a decision after a design change or after the control lists are updated. Controls change, so schedule reviews.

Frequently Asked Questions

What is the difference between USML and ECCN?

The USML lists defense articles controlled under ITAR by category. ECCNs are entries on the Commerce Control List under the EAR for dual-use and less sensitive items. An item is normally controlled under one regime, and jurisdiction must be settled first.

Can I self-classify?

For EAR items you may self-classify using the Commerce Control List. For ITAR, you may self-determine that an item is a defense article, but a commodity jurisdiction request is available when jurisdiction is genuinely unclear. Document your reasoning either way.

What is EAR99?

EAR99 is the designation for items subject to the EAR but not listed on the Commerce Control List. They generally need no license except for certain destinations, end users or end uses, so screening still applies.

How often should I review?

At least annually, and whenever a design changes, a new product enters the catalog or the control lists are revised. Set the next review date on each row so overdue items are easy to find.

Netray can discuss carrying classification flags into your ERP item master so shipping and document release respect them. The worksheet is free and standalone.

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