To find the ECCN for electronic components under the EAR, follow the Commerce Control List Order of Review: rule out the U.S. Munitions List, the 600 series and the 9x515 entries, compare the part's datasheet values with ECCN 3A001 in Category 3, and then with 3A991, the entry for electronic devices and components not controlled by 3A001. If no ECCN describes the part, it is EAR99. The answer usually turns on a few rated values (operating temperature range, clock frequency, I/O count, sample rate, RF frequency and output power) and on what the part was designed for.
Finding the ECCN for electronic components step by step
The sequence comes from Supplement No. 4 to Part 774:
- Confirm the part is not a defense article. The Related Controls note in 3A001 points to USML Category XI for certain ASICs, MMICs and transmit/receive modules, and to Category XV for certain space-qualified electronics (see how to decide between ITAR and EAR).
- Check the 600 series and 9x515 entries, which take precedence over other ECCNs. 9A515.d and .e cover radiation-hardened microelectronic circuits and discrete components that meet the radiation thresholds listed there and are "specially designed" for the defense articles, 600 series items or spacecraft items those paragraphs name. 3A611.f covers ASICs and programmable logic devices programmed for 600 series items.
- Read Category 3, product group A, from the beginning of the group. For most components that means 3A001; 3A090 for advanced computing chips (covered in the guide to semiconductor export controls); 3A101 and 3A201, controlled for MT and NP reasons respectively; 3A901 for cryogenic CMOS integrated circuits and parametric signal amplifiers; and 3A991.
- Where an entry uses "specially designed" as a control parameter, apply the catch and release test in § 772.1 (see the specially designed definition).
- If nothing on the CCL describes the part, it is EAR99.
A component can also sit outside Category 3. Some entries in other categories control parts "specially designed" for the equipment they list, and Part 772 gives the heading of 7A102, which controls "specially designed" components for certain gyros, as an example of such a catch-all (see the ten CCL categories).
How Category 3 sorts components into 3A001, 3A991 and EAR99
ECCN 3A001 is controlled for NS, RS, MT, NP and AT reasons, with NS Column 2 applying to the whole entry. Each paragraph names a type of component and the value it must reach. Paragraph a covers general purpose integrated circuits and b microwave and millimetre wave items; the later paragraphs cover acoustic wave devices, high energy cells and capacitors, power semiconductors and a few other types.
ECCN 3A991, "Electronic devices, and 'components' not controlled by 3A001", is controlled for AT reasons only, and License Exceptions LVS and GBS are not available for it. Several of its paragraphs repeat 3A001 product types at lower thresholds. Note 1 to the "specially designed" definition in § 772.1 treats 3A991 as an ECCN controlled exclusively for AT reasons. Some of the release provisions depend on that status. Paragraph (b)(3), for example, releases a part with the same function, performance and form and fit as one used in a production item that is described in an AT-only ECCN.
EAR99 covers items subject to the EAR that no CCL entry describes. It is not an ECCN, and an EAR99 part can still need a licence. The EAR99 confirmation check applies to components as it does to finished goods.
Which datasheet values decide 3A001 or 3A991?
The table summarises the current text in Supplement No. 1 to Part 774. Notes and technical notes define how each value is measured, so read the full paragraph before you decide (how to read an ECCN entry explains the layout).
| Component | 3A001 | 3A991 |
|---|---|---|
| Microprocessors and microcontrollers | a.2: rated above +125 °C, below −55 °C, or over the entire −55 °C to +125 °C range. a.3: compound semiconductor, clock above 40 MHz. | a: clock frequency exceeding 25 MHz, or 5 GFLOPS or more with an ALU access width of 32 bit or more (a.3 adds a test for parallel interconnection ports). |
| Memory ICs | a.2: SRAMs, non-volatile memories and compound semiconductor storage ICs with the a.2 temperature ratings. | b: flash EEPROM over 16 Mbit per package; other EEPROM and SRAM over 1 Mbit (lower capacities with fast access times are also listed). |
| Analog-to-digital converters | a.5.a: by resolution and sample rate, for example 12 to under 14 bit above 400 MSPS. Also a.2. | c: for example 12 bit with an output rate above 105 million words per second. |
| FPGAs and CPLDs | a.7: more than 700 single-ended digital I/O, or an aggregate one-way peak serial transceiver data rate of 500 Gb/s or more. Also a.2. | d: maximum single-ended digital I/O between 200 and 700. The technical notes to p also name field programmable logic devices. |
| Custom ICs whose function or end equipment is unknown to the manufacturer | a.10: more than 1,500 terminals, gate delay under 0.02 ns, or operating frequency above 3 GHz. | f: more than 144 terminals, or propagation delay under 0.4 ns. |
| Integrated circuits not elsewhere specified, such as CPUs, GPUs and AI accelerators | No paragraph of its own. See 3A090, and 3A001.z for 3A001 items that also meet 3A090. | p: 8 TOPS or more, or an aggregate bidirectional transfer rate of 150 Gbyte/s or more to or from ICs other than volatile memories. |
| Electrochemical cells | e.1: for example secondary cells above 350 Wh/kg at 20 °C. | j: primary cells of 550 Wh/kg or less; secondary cells of 350 Wh/kg or less. |
| Power MOSFETs, IGBTs and diodes | h: junction temperature above 215 °C, blocking voltage above 300 V and continuous current above 1 A, all three. | No matching paragraph. |
Some notes change these results. 3A001.a.2 does not apply to integrated circuits designed for civil automobile or railway train applications, and 3A001.h does not apply to parts incorporated into equipment designed for civil automobile, civil railway or civil aircraft applications. Both 3A001.e and 3A991.j exclude batteries, including single-cell batteries. A part rated −40 °C to +85 °C meets none of the a.2 temperature tests, so the analysis moves on to speed and size.
For RF parts, 3A001.b.2 (MMIC amplifiers) and b.3 (discrete microwave transistors) set power limits band by band. You need the rated frequency range, the peak saturated power output (the technical note says datasheets may call it "output power" or "maximum power output") and, for most MMIC bands, the fractional bandwidth. A chip with information security functions needs one more check, because 5A002 controls "information security" components too (see encryption controls under 5A002).
When the end equipment decides the component's ECCN
Product group A of Category 3 opens with notes that can settle a component's status before you compare any figures. Under Note 1, items described in 3A001 (other than a.3 to a.10, a.12 to a.14, b.12 and z), 3A002 or 3A901 that are "specially designed" for, or have the same functional characteristics as, other equipment take the control status of that equipment. Note 2 does the same for integrated circuits in 3A001.a.3 to a.9, a.12 to a.14 and z, or 3A901, that are unalterably programmed or designed for a specific function for other equipment. If the manufacturer or applicant cannot determine the status of that equipment, the IC is assessed against those paragraphs.
Note 3 to 3A001.b.2 applies this to MMICs: 3A001.b.2 does not control MMICs "specially designed" for other applications, such as telecommunications, radar or automobiles. Take a hypothetical MMIC amplifier built for one civil radio link whose figures would meet 3A001.b.2. The radio's control status decides the MMIC's, so you classify the radio first.
Programming can move a part as well. A catalogue FPGA is classified on its own figures, but once programmed for a 600 series item it is described in 3A611.f, and the 3A611 Related Controls place programmable logic devices programmed for ITAR defense articles in USML Category XI(c)(1). A part developed as a general purpose commodity, with no knowledge of a particular end item or type of end item, is released under § 772.1(b)(5) wherever "specially designed" is the control parameter.
What ECCN do capacitors, connectors and other passive parts have?
Two Category 3 entries set technical thresholds for capacitors. 3A001.e.2 covers high energy storage capacitors, and every type it lists has a voltage rating of 5 kV or more plus energy density and total energy floors (for single shot capacitors, 250 J/kg and 25 kJ). 3A201.a, controlled for NP reasons, covers pulse discharge capacitors above 1.4 kV, 10 J and 0.5 µF with series inductance below 50 nH, or above 750 V and 0.25 µF with series inductance below 10 nH. A capacitor rated at 750 V or less cannot meet either entry. Separately, 3A999.c lists high voltage capacitors among the parts and components of pulsed power systems in its flash X-ray paragraph, with licence requirements for Iraq, Pakistan and North Korea.
3A991 has no paragraph for capacitors, resistors or connectors, and if no other entry describes them they are EAR99. The exception is the military supply chain: 3A611.y lists electrical connectors, mica paper capacitors, potentiometers, fixed resistors and electric transformers "specially designed" for a 600 series item or a defense article (see how 600 series .x and .y paragraphs work). The release in § 772.1(b)(2) covers fasteners, washers, spacers, insulators, grommets, bushings, springs, wire and solder regardless of form or fit. Connectors and capacitors are not on that list.
Can you use the manufacturer's ECCN?
BIS guidance on its Classify your item page lists asking the manufacturer as one of three ways to find an ECCN, and warns that ECCNs may change over time, so the ECCN should be reviewed against the current CCL. See where to find manufacturer ECCNs for the usual sources.
ECCN.help's suggestion is to check a published ECCN against the datasheet values above for each order code. A part family sold in commercial, industrial and −55 °C to +125 °C grades can carry a different ECCN for each grade. Classify the part yourself when you program or modify it, or when it is made to your design, because the manufacturer's answer then describes a different item.
Worked example: a hypothetical 12-bit ADC
Take a hypothetical single-channel 12-bit analog-to-digital converter sampling at 125 MSPS, rated −40 °C to +85 °C, developed as a general purpose part. It is not radiation hardened and is not described on the USML.
- No 600 series or 9A515 paragraph describes it.
- 3A001.a.2 does not apply: the rated range meets none of the three temperature tests.
- 3A001.a.5.a.3 needs a sample rate greater than 400 MSPS for 12 to under 14 bit. At 125 MSPS the part falls short.
- 3A991.c.2 covers 12 bit with an output rate greater than 105 million words per second. At one word per sample the part exceeds that, so it is 3A991.c.2.
The same die sold in a grade rated over the entire −55 °C to +125 °C range meets 3A001.a.2.c and moves to 3A001, with NS controls. A version sampling at 100 MSPS falls below 3A991.c.2 and, if nothing else describes it, is EAR99.
What the classification means for licensing
For 3A001, read the destination against NS Column 2 and AT Column 1 in the Commerce Country Chart, plus the NS Column 1, RS, MT and NP rows for particular paragraphs. Where License Exception LVS is available, its value limit is $1500, $3000 or $5000 depending on the paragraph. It is not available for the MT and NP items, for 3A001.z, or for b.2 and b.3 items unless they are exported or reexported for use in civil telecommunications applications.
For 3A991 the only CCL reason is AT Column 1, which brings licence requirements for Iran, Syria and North Korea under §§ 742.8, 742.9 and 742.19. Cuba, North Korea and Syria are also covered by embargo rules in §§ 746.2, 746.4 and 746.9 that require a licence for nearly all items subject to the EAR, EAR99 included. Section 746.8(a)(1) requires a licence for Russia and Belarus for any item in any ECCN. Under § 744.17, a licence is needed for microprocessors of 5 GFLOPS or more with an ALU access width of 32 bit or more when you know, have reason to know or are informed by BIS that they are for a military end use or military end user in Country Group D:1.
EAR99 parts have no CCL licence requirement but stay subject to end-use, end-user and embargo rules. For Russia and Belarus, Supplement No. 4 to Part 746 lists, by HTS code, capacitors (8532), resistors (8533), diodes and transistors (8541) and integrated circuits (8542). BIS also publishes the Common High Priority Items List, items identified by six-digit HS codes, integrated circuits among them, that BIS says carry a heightened risk of diversion to Russia.
What to do next
Pull the datasheet for the exact order code and note the rated temperature range, clock frequency, I/O count, converter resolution and sample rate, RF band, peak saturated power and fractional bandwidth, and anything about radiation hardness or encryption. Run the Order of Review, record the paragraph that decided the result, and file it with the datasheet revision you used.
Electronic components in ECCN.help
ECCN.help applies rules taken from the published EAR, with no language model, and each answer names the entry and paragraph that decided it. The workflow checks ITAR vs EAR jurisdiction first, asks only for the values the candidate entry turns on, and records each ruled-out entry when it reaches EAR99. Start with Quick Search on the home page or read how the classification workflow runs, and enter ordinary product descriptions, never controlled technical data.
ECCN.help provides research and assistance, not legal advice. Verify every result against the current regulation before you rely on it.