Questions and answers about ECCN

  • 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 […]


    QUESTION:It is a common practice in laser manufacture to increase the frequency of a laser by lowering the wavelength using harmonic generation.  (Frequency and wavelength are inversely proportional.)  1064 nanometers (nm) is the fundamental output of a laser.  Applying a second harmonic generator shortens the wavelength to 532 nm, thereby doubling the frequency.  Note this is […]

  • Best Practices to review ECCN’s/MEU’s

    QUESTION: What are some of the best practices is the group using to review ECCNs subject to MEU for China, Russia, and Venezuela? Is anyone using 3rd party reports to identify red flags for end users in these countries? =========== Answers: Yes, we have a form that we use to provide guidance on what we […]


    QUESTION: I need assistance with assigning an ECCN to a kit/assembly. Half of our team is of the belief that the ECCN should be based on the technical characteristics of the end-product. Example- shipping components (some assembled, some not) in one box and assigning the ECCN based on the characteristics of the product once assembled, […]


    QUESTION: Do I understand correctly that for a pump classifiable under ECCN# 0A998.b.3, a part shipped separately (e.g. body casting) would not itself be classifiable under ECCN# 0A998.b.3 rather that would be EAR99? Also, for a part to be classifiable under an ECCN it would need to be specifically called out, for example in ECCN […]


    OT Fact Sheet: Origin Certification Requirements QUESTION: I’m guessing I know the answer already, but true or false . . .there is no good translation from UNSPSC codes to ECCN or USML. United Nations Standard Products and Services Codes (UNSPSC) ****************** Answers: No direct translation.    As an aside, there was an effort in a […]


    OT Fact Sheet: Origin Certification Requirements QUESTION: We currently do not indicate ECCN on our invoice for export shipments, the Customer is requesting ECCN on the Invoice. We are the USPPI and complete EEI filing with our designated Agent. ECCN and NLR is indicated on the EEI.  Is the ECCN still required on Invoicing for […]