Questions and answers about ECCN

  • Medicine ECCNs

    Question: My understanding is that almost all medicines are considered EAR99 except for vaccines, “immunotoxins” (antibody-toxin conjugates intended to destroy specific target cells such as tumor cells that bear antigens homologous to the antibody), certain toxin containing medical products, and diagnostic and food testing kits are controlled under ECCN 1C991, 1C395, or 1C995.  However, I’m […]

  • SAP

    Question: Hi, This is a question for all the SAP users out there. We have ShipErp “bolt on” to our SAP platform, but I am told that ShipErp DOES NOT support the info needed for exporting very well. i.e. schedule B#, ECCNs, etc.  I am finding this out the hard way. Does anyone in the […]

  • Deemed export? Do I need to limit access to servers for internal employees?

    Question: Our organization had to send server to update our IT system to EU. The server falls under 5a992 c.. There is and AT control but NLR to Poland. Do I need to limit access to the server by anyone who could be citizen of N.Korea, Syria, Iran, Cuba etc. (if any)? Would this be […]

  • Dual Use Items incorporated into EAR99 items

    Question: If a dual-use valve is incorporated into another item, for example a pump, is the pump now considered controlled as dual use? Answer 1: EAR 770.2(b) addresses your question. As a general rule in the EAR, an assembled item is classified in the form in which it is exported, regardless of the classifications of […]

  • ECCN Finished Goods

    Question: So I want to submit a classification request to BIS for a finished overhead scale. I know I have to send details of components. What is the Membership’s experience with finished items vs some of the individual items that may appear on the control list? Example: This scale has a loadcell and maybe other […]

  • ECCN lookup tool, API, or database?

    Question: My company develops global logistics solutions for the Federal Government. Users must enter ECCN numbers for all parts involved with shipments. We are trying to make it easier for users to lookup ECCN numbers for known parts. Is there a database, API, or lookup tool that can search ECCN# by Part number? Seems the […]

  • Destruction of a licensable(?) item

    Question: We have an EAR99 item.  One of the components, if shipped alone, would be 7Axxx (NS, AT). Question:  The EAR99 item is shipped somewhere, correctly and legally.  But the licensable component needs to be removed and destroyed. Who can do the removal and destruction?  A US person or anyone? Answer 1: You’re sort of […]

  • ECCN Classification J85, and other engine parts

    Question: Is there such thing as “ECCN” database/search engine that we can pay and subscribe?  I am fully aware that ECCN classification is the exporter’s responsibility (or to self-classify). But there are times when classification can be a big challenge, and this is also true if you don’t have the correct OEM’s contact info or […]

  • Training ECCN/EMBARGO

    Question: Does anyone have any training material that would help simplify the training process Internal Departments for ECCN, EMBARGOS, EXPORTS Answer 1: Content Enablers licenses its training content for companies to use at the facility level or throughout a global organization. You can see the list of content in our catalog, and if you want […]

  • Regulation requirements when changing an ECCN classification

    Question: Is there any regulation or guidance available on requirements for changing a classification.  If a part is manufactured for use in a military application and a civil application, the classification would be in a “600 Series” ECCN.   A new part is to be designed for an identical use but only in a civil application […]

  • 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 […]