The Commerce Country Chart is the table in Supplement No. 1 to Part 738 of the Export Administration Regulations (EAR) that tells you whether an item needs a licence for a given destination. You take the reasons for control from the item's ECCN, find the destination row and look for an "X" in the matching columns. An X means a licence is required unless a licence exception applies. No X means no licence is required on the basis of the chart, although embargoes and end-use and end-user controls still apply.
Put another way, the ECCN tells you why an item is controlled and the chart tells you where that control bites. The steps below show how to read the chart.
Where is the Commerce Country Chart?
The chart is Supplement No. 1 to Part 738 of the EAR. Rows are destinations. Columns are reasons for control, split into numbered columns: NS1 and NS2, MT1, NP1 and NP2, CB1 to CB3, RS1 and RS2, CC1 to CC3, FC1, AT1 and AT2. Our page on reasons for control explains what each code means.
All destinations are listed. If a name looks unfamiliar, check how the country or territory is listed. The chart also changes with new rules, so use the current version and record the date you checked it.
Step 1: Get the reasons for control from the ECCN
Open the entry and read its License Requirements section. Each line gives a reason and the chart column to check, and a line may apply only to some paragraphs. For example, an entry might say: NS applies to entire entry: NS Column 2; AT applies to entire entry: AT Column 1. Your item's paragraph decides which lines apply, so check the columns that paragraph lists. Checking every column gets the answer wrong, and so does skipping one that the paragraph lists. Our guide on how to read an ECCN entry walks through the section line by line.
An item classified EAR99 does not use the chart at all. EAR99 items have no reasons for control on the chart. Their licence requirements come from embargoes and from end-use and end-user controls.
Step 2: Find the destination row
Use the country of ultimate destination, meaning the country where the item will be used. A country the shipment only passes through is the wrong row. Reexports of items subject to the EAR work the same way: you assess them against the new destination.
Step 3: Check each relevant column
For each reason and column listed for your paragraph, look at the cell for your destination. An "X" means a licence is required for that reason. One X is enough.
Step 4: If there is an X, look for a licence exception
The entry's List Based License Exceptions section and Part 740 may allow the export without a licence. LVS, GBS, STA and ENC are examples, each subject to its own conditions and to the restrictions in § 740.2. See the overview of licence exceptions and the guide to License Exceptions TMP, STA and GOV.
Step 5: If there is no X, check the other controls
"No licence required" (NLR) under the chart does not override these controls:
- embargoes and sanctions in Part 746 and the OFAC programmes (see country sanctions and embargoes);
- end-use controls in Part 744, such as weapons of mass destruction and certain military end uses;
- end-user controls, which come from the Entity List and the other restricted party lists.
Our guide on when an export licence is required sets out the full sequence.
Country Chart licence requirements: a worked example
Take a component classified 3A001.b.3, and suppose its License Requirements show NS (Column 2) and AT (Column 1).
If the destination is Germany, the Germany row has no X under NS2 and none under AT1. The result is NLR on the chart, subject to screening and end-use checks.
If the destination is a country with an X under NS2, a licence is required unless a licence exception applies. For destinations in Country Group D:1 few exceptions are available, so in practice this usually means a licence application.
The columns shown here are for illustration. Always read the entry's own License Requirements.
Country Groups: the other table you will need
Many licence exceptions refer to the Country Groups (A, B, D, E) in Supplement No. 1 to Part 740, and the Country Chart does not show them. Group B, for example, is used by License Exception GBS, and Groups D and E flag destinations of concern. Keep both tables at hand.
How ECCN.help checks the Country Chart for you
The ECCN.help licence check does steps 1 to 4 for you. Starting from a classification made in the rule-based ECCN.help Classification Workflow, it reads the paragraph's reasons for control against the chart for your destination, lists the exceptions to consider and shows each column it checked.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.