Questions and answers about ECCN

  • ECCN 1C992 – License requirement interpretation

    Question: We are exporting a product classified as 1C992 to Italy.  We have differing interpretations of how to determine if a license is required.  The License Requirements under 1C992 read as follows: Control(s)                                           Country Chart […]

  • Wafer Die ECCN

    Question: For ECCN of a wafer die in which the integrated circuit is classified under Category 5 due to encryption be classified under Category 3 or Category 5?Note 3 in Category 3 points finished wafer to 3A however unsure with encryption angle. Note: 3The status of wafers (finished or unfinished), in which the function has […]

  • Export classification

    Question: what classification may a machine that  is used for testing of hermetically sealed microelectronic and optoelectronic devices. Answer 1: If you cannot find an HTS for this machine then it would have to be classified as 8479.90.9596 Answer 2: Lots of possibilities here depending largely on the specific type of machine, and whether is […]

  • Question on correct ECCN for 5-Port 10/100/1000Mbps Gigabit Ethernet Unmanaged Switch

    Question: I am looking for advice on the correct export classification for a 5-Port 10/100/1000Mbps Gigabit Ethernet Unmanaged Switch.  During research I have seen this classified as both EAR99 and 5A991.  I suspect 5A991 is correct, however, given the inconsistency of available details, I would value expert opinion on this, if available.  We have also […]

  • 3A991

    Question: Does anybody deal with  automotive electronics in their expertise? ? Mostly ATV, motorcycle 12 V stuff.  I am questioning whether CDI boxes ( capacitor Discharge Ignitions ) would fall under 3A991.  Currently it’s under EAR99 because I don’t believe  these particular items were originally designed for Military use.  But the more I read, it […]

  • ECCN classification of a system that incorporates a dual-use item

    Question: What are the rules around classifying a larger system / assembly of components that incorporate one controlled component (e.g. a pump) and the rest of the components are EAR99? Answer 1: You mention EAR99 so I assume you are classifying under the EAR; the rule is you CLASSIFY THE END ITEM.  The classification of […]

  • Expired ECCN on an existing license

    QUESTION: We have a Commerce Department license issued in 2020 for an ECCN whose subcategory was recently removed – changed to “Reserved” in the CCL – but our license doesn’t expire until 2024.  Is our license still valid?  When will happen when the EEI is filed with the ECCN and the license number?  %%%%%%%%%% ANSWERS: Typically […]

  • ECCN Determination

    QUESTION: Who is typically responsible for determination of the ECCN, the U.S. Exporter (USPPI) or the Supplier/Manufacturer who sells domestically to the USPPI? %%%%%%%%% We have always had the manufacturer of the item provide the jurisdiction and classification of the item. If the manufacturer is unable to provide the determination, then the exporter of the […]


    QUESTION: What documents should an ECCN classification be listed on for an export entry packet? =========== Answers: The commercial invoice and the Shipper’s Letter of Instruction (SLI) ============ There is no “entry packet” because the ECCN  is used for exports, and entries are what we do for imports.  The ECCN goes on the SLI for […]

  • ECCN number for PCB evaluation board ( printed circuit assembly)

    QUESTION: Does ECCN apply to PCB evaluation board ( without software) designed to change the channels of optical transceivers ? I went through category 5 : ECCN for optical transceivers is 5A991 ( sold separately) Couldn’t determine / find anything related to the basic printed circuit assembly evaluation board to be used for programming ( […]


    QUESTION: Can the membership comment on what the ECCN may be for an internet protocol camera available on line for $75.00? ************* Answers: Provided that it doesn’t have thermal attached to it (which by the amount of the camera) it should be EAR99. Our IP cameras except for the thermal list as EAR99 ************ This […]

  • More than a single ECCN subparagraph apply

    QUESTION: A recent classification process ultimately found more than one ECCN and subparagraph match our product: XXXXX.b.6.c.1.b and XXXXX.b.6.c.1.e.  Same top-level ECCN, just different subparagraphs.  I’d always assumed that one would drill down to a single subparagraph. Does one use the first subparagraph as that might be conceived as a higher level of control? Is there a […]