Every item exported from the United States — or re-exported from abroad when it contains U.S. content — needs an export classification before anyone can say whether a licence is required. For most commercial products that classification is an Export Control Classification Number (ECCN) on the Commerce Control List (CCL), or EAR99 when no entry describes the item. This guide walks through how to find it, in the order the regulation itself sets.
Before you start: what you need to know about the item
An ECCN is decided by what the item is and what it can do, not by what it is called or who buys it. Gather these first:
- What it is — a physical product (equipment, part, component, material), software, or technology (technical data or know-how). The CCL treats them in different product groups.
- Its function and technical parameters — frequencies, speeds, accuracies, operating temperatures, processing performance, encryption functions. The CCL is written in these terms.
- Its design history — whether it was developed for a military or space application, or specially designed for another controlled item.
- Any information-security function — encryption for confidentiality points to Category 5, Part 2.
Datasheets and published specifications are usually enough. You do not need, and should not share, controlled technical data to classify an item.
Step 1: Settle jurisdiction — ITAR or EAR?
Classification starts with jurisdiction. If the item is a defense article described on the U.S. Munitions List (USML), it is controlled under the International Traffic in Arms Regulations (ITAR) and has no ECCN. Only when the item is not on the USML does it become subject to the Export Administration Regulations (EAR). See ITAR vs. EAR: which regulation controls your item? for how to make that call, and when to ask for a commodity jurisdiction determination.
Step 2: Follow the Order of Review
Supplement No. 4 to Part 774 of the EAR sets the Order of Review. In short: check the USML first; then the "600 series" entries (military items moved from the USML); then the 9x515 spacecraft entries; then the rest of the CCL; and only if nothing matches, EAR99. Following this order matters because a more specific entry takes precedence over a general one — an item that fits a 600 series entry is classified there even if a general entry could also describe it.
Step 3: Choose the CCL category (0–9)
The CCL is divided into ten categories by technology area. Pick every category that could plausibly apply:
- 0 — Nuclear materials, facilities and equipment, and miscellaneous items
- 1 — Special materials, chemicals, microorganisms and toxins
- 2 — Materials processing
- 3 — Electronics
- 4 — Computers
- 5 — Telecommunications (Part 1) and information security (Part 2)
- 6 — Sensors and lasers
- 7 — Navigation and avionics
- 8 — Marine
- 9 — Aerospace and propulsion
The ten CCL categories explained gives examples of what sits in each.
Step 4: Choose the product group (A–E)
Inside each category, entries are grouped by what the item is: A systems, equipment and components; B test, inspection and production equipment; C materials; D software; E technology. Software is never classified in group A, and technology is never classified in group D — the product group follows from what you are exporting. See CCL product groups A–E.
Step 5: Read the candidate entries — and match the paragraph
Now read the entries in that category and group. Each entry has a heading, a list of controls (the reasons for control), related definitions, and — most importantly — the Items paragraph with the technical parameters. The item is described by an entry only if it meets the paragraph's parameters, not merely its heading. A radio receiver is not 5A001 because it is a radio; it is 5A001.b.5 only if it has every characteristic that paragraph lists.
Two definitions decide many cases:
- "Specially designed" (§ 772.1) — a two-step test of "catch" and "release" that determines whether parts, components and software are controlled with the item they are made for. See the specially designed definition.
- Notes and exclusions — many entries exclude items by note (for example, equipment specially designed for civil use). Read them before concluding.
How to read an ECCN entry walks through the structure of an entry field by field.
Step 6: Check the "catch-all" 9xx entries
If the item does not meet a multilateral entry (the 0xx–5xx numbers), check the entries numbered 9xx in the same category and group, such as 3A992 or 5A991. These are controlled mainly for anti-terrorism reasons and often catch commercial items that fall below the multilateral thresholds.
Step 7: Conclude — the ECCN, or EAR99
If an entry and paragraph describe the item, that is its ECCN — for example 5A992.c. If, after reviewing every category and group that could apply, no entry describes it, the item is EAR99: subject to the EAR but not listed. EAR99 is a conclusion you reach, not a default; see What is EAR99?.
Step 8: Record how you got there
Write down the entry, the paragraph, the parameters you compared, the version of the regulation you used and the date. If a customs officer, an auditor or BIS asks, that record is your justification — and it lets you revisit the decision when the CCL changes.
Shortcuts that help — and their limits
- The manufacturer's ECCN. Many manufacturers publish ECCNs for their products. It is a good starting point, but you remain responsible for the classification you use. See where manufacturers publish their ECCNs.
- The CCL alphabetical index. Supplement No. 1 to Part 774 has an index by commodity name — useful to find candidate entries, never a classification on its own. See ECCN lookup: how to look up an ECCN.
- A formal ruling. When the answer is genuinely unclear, BIS will classify the item on request. See self-classification vs. a BIS request.
Do it step by step with ECCN.help
The ECCN.help Classification Workflow follows exactly this sequence — ITAR vs. EAR first, then the category and product group, then the candidate entries and the paragraph the item meets — asking only what the regulation turns on and showing the rule that decided every answer. It is rule-based, with no AI, and every account includes five classifications. The How to use page shows three worked examples, from a cryogenic bearing to a consumer Wi-Fi router and an EAR99 water bottle.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation and obtain a formal classification where the stakes require one.