Why are ECCNs Important?
Export Control Classification Numbers (ECCNs) are essential as they determine what licenses are required for the goods being imported/exported based on their characteristics. ECCNs may also indicate that certain goods are banned from the destination or reveal blacklisted traders. Since these goods have military implications, incorrectly classifying goods can have severe repercussions.
The Structure of an ECCN
ECCNs are made up of five characters. To break down an ECCN, you need to look at the CLL. The CLL is divided into categories, each consisting of five products.
- The first character is a number between zero and nine (0-9). This indicates the CCL category, with category 10 represented with a zero.
- The second character is a letter referring to the product group and ranges between A and E.
- The final three numerical values in an ECCN number refer to the level of control that applies to that item.
How to Find an ECCN Number
If you require an ECCN for your anticipated export, several choices are available to you, including speaking with the manufacturer, who might already possess an ECCN.
You could also search through the categories of the Commerce Control List and find the ECCN that most closely matches your product.
Alternatively, by utilizing the BIS multipurpose application form BIS-748P, you could send a letter to BIS requesting your ECCN. Apply early because this could take 3 to 4 weeks.
The Difference Between ECCNs and HS Codes
Harmonized System codes or HS codes and ECCNs have similarities but are considered independent. Both HS codes and ECCNs describe the nature of the product and classify them accordingly. That is where the similarity begins and ends.
While ECCNs dictate what licensing is required, HS codes determine the duties and taxes associated with that product. Numerous factors influence the ECCN number and licensing requirements of a particular product. This means one HS code may have several ECCNs and vice versa.
What is an EAR99?
Suppose your goods are subject to Export Administration Regulations (EAR), but are not listed on the Commerce Control List with a specific Export Control Classification Number (ECCN). In that case, they will be issued as EAR99.
EAR99 is the classification for items that do not need an export license in most cases, and this applies mostly to low-technology consumer goods due to their basic specifications.
However, careful diligence is still required of the exporter in these instances to ensure that goods are not entering an embargoed country or end-use, in which case an export license may be required.
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