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Export Control Classification Number (ECCN) Determination

If something is subject to the EAR, then we need to determine the applicable export control classification number (ECCN).

Here’s a summary of what the ECCN letters and numbers actually mean.  Items controlled under the EAR, and their associated ECCNs, appear on the Commerce Control List.  The Commerce Control List is broken down into Categories 0 through 9:


Category 0 - Nuclear Materials Facilities & Equipment [and Miscellaneous Items]

Category 1 - Materials Chemicals Microorganisms and Toxins

Category 2 - Materials Processing

Category 3 - Electronics Design Development and Production

Category 4 - Computers

Category 5 Part 1 - Telecommunications

Category 5 Part 2 - Information Security

Category 6 - Sensors and Lasers

Category 7 - Navigation and Avionics

Category 8 - Marine

Category 9 - Aerospace and Propulsion

The first number in an ECCN represents which Category 0 through 9 it is associated with. The letter identifies which product group the ECCN is for:

A. Systems, Equipment and Components
B. Test, Inspection and Production Equipment
C. Material
D. Software
E. Technology

The three numbers following the letter provide further categorizations and ordering of the ECCNs. For example, generally speaking, higher numbered ECCNs (e.g. 3A999) have fewer export restrictions than lower numbered ECCNs (e.g. 3A001).

Also, keep in mind that a system, piece of equipment, component and/or material (e.g. having an ECCN with an “A”, “B” or “C” in it, may have associated software (having an ECCN with a “D” in it) and/or technology (having an ECCN with a “D” in it) (note: “technology” under the EAR pertains to information). Each ECCN has specific reasons for control that we will get into a bit later.

In addition, remember that even if a particular software or information/technology may have an ECCN that relates to it, if that software or information/technology is published, the product of fundamental research and/or is released by instruction in a catalog course or associated teaching laboratory, then that software and/or information/technology is not subject to the EAR.

Determining the applicable ECCN:
For any given item, there are three different ways to figure out the ECCN:

  • ask the manufacturer (they likely will know the ECCN), and then verify the ECCN based on your own technical understanding of the item
  • self determine the ECCN by reviewing the Commerce Control List
  • ask the Department of Commerce to make a determination on the ECCN (please consult with the University’s Export Control Officer, Josef Mejido before proceeding with this approach)

In case you don’t know which Category of the Commerce Control List to search, you can try doing key word searches in the Commerce Control List index or the compiled PDF with Commerce Control List Categories 0 through 9 combined in one document. Note that it is sometimes necessary to try various key word searches before finding a particular ECCN.

If an item does not specifically appear on the Commerce Control List, then instead of getting a specific ECCN it’s designated under a catchall category “EAR99”. Examples of EAR99 items include a bicycle, coffee mug, pen.

Once you know the applicable ECCN for an item, you can then determine if an export license is required for the specific scenario you are interested in.