ECCN

Does everyone who exports goods or services from the United States need Export Control Classification Numbers (ECCNs)? The simple answer is no. These numbers refer to various commodities, technologies, and software that might fall under the purview of U.S. export controls.

What is ECCN?

The primary use of ECCNs is to adhere to U.S. export control requirements. This classification system helps determine the level of control that applies when an item is exported from the U.S. or is re-exported. It plays an important role in establishing if you need an export license in the first place.

It is not just the Department of Commerce that has a say in export controls in the U.S. In some instances, multiple departments collaborate in the classification of a single item. The other departments that play in role in this classification system include:

  • Nuclear Regulatory Commission (NRC)
  • Department of Energy (DOE)
  • Department of Homeland Security (DHS)
  • Department of the Treasury’s Office of Foreign Asset Control (OFAC)
  • Department of State’s Directorate of Defense Trade Control (DDTC)
  • Food and Drug Administration (FDA)
  • Department of the Interior (DOI)

An ECCN is a five-character alpha-numeric designation found in the Commerce Control List (CCL). Products are categorized based on their nature (type of commodity, software, or technology) along with their technical parameters. The structure they follow remains the same.

  • The first character is the category number.
  • The second character is the product group letter.
  • The third character provides the control reason.
  • The fourth character distinguishes between multi and unilateral concerns.
  • The last character is used as a sequential number.

Commerce Control List categories are listed in the corresponding table.

0 - Nuclear materials, facilities and equipment (and miscellaneous items)

1 - Materials, chemicals, microorganisms, and toxins

2 - Materials processing

3 - Electronics

4 - Computers

5 - Telecommunications and information security

6 - Sensors and lasers

7 - Navigation and avionics

8 - Marine

9 - Propulsion systems, space vehicles, and related equipment


The product groups are as follows.

A - Systems, equipment, and components

B - Test, inspection, and production equipment

C - Material

D - Software

E - Technology


Organization in Charge of ECCN

The Bureau of Industry and Security, a part of the U.S. Department of Commerce, is responsible for the administration of Export Administration Regulations (EAR). EAR is a set of regulations as defined in 15 C.F.R. § 730 et seq. The Commerce Control List (CCL) is part of the EAR, and it provides alpha-numeric ECCNs.


History of ECCN

Export control regulations for the export of goods and technology have existed in the United States since the 1940s. Attention to compliance has increased significantly in recent times, mainly because of concerns surrounding homeland security, terrorism, proliferation of weapons of mass destruction (WMDs), drug trafficking, as well as leaking of sensitive information outside of the country.

The Wassenaar Arrangement, a multilateral arrangement that addresses export controls on conventional arms as well as sensitive dual use goods and technologies, was founded in 1996. It replaced the then in use East-West technology control program. Member states of the Wassenaar Arrangement work in ensuring that they detect and deny undesirable exports. They also periodically refine prevailing Control Lists to make them more user-friendly and easily understandable.


Example Codes

Here are a few ECCNs.

1C003

1C004

1C005


The first number (1) in these examples denotes the category (Materials, chemicals, microorganisms, and toxins).

The second character (C) represents the product group (Material).

The third character (0) identifies the control reason (National security reasons).

The fourth character (0) represents a multilateral concern.

The codes, in their entirety, with the last digit being a sequential number, represent:

  • 1C003 – Magnetic metals, of all types and of whatever form
  • 1C004 – Uranium titanium alloys or tungsten alloys with a matrix based on iron, nickel, or copper
  • 1C005 – Superconductive composite conductors exceeding 100 meters in length or with mass exceeding 100 grams