Finding a candidate ECCN is only half the work, because the classification is decided inside the entry. To read an ECCN entry on the Commerce Control List (CCL), go through its blocks in order: the heading, License Requirements with the reasons for control, List Based License Exceptions, and the List of Items Controlled with its notes and definitions. Every ECCN under the EAR uses this layout, so once you can read one entry you can read them all.
If you do not have a candidate entry yet, start with how to find the ECCN for your product.
What are the parts of an ECCN entry?
1. The heading
The entry begins with the ECCN and a heading, for example "5A992 Equipment not controlled by 5A002" or "7A001 Accelerometers, as follows". The heading tells you the kind of item covered. It does not classify your item on its own: many items fit a heading and still fall outside every paragraph of the entry. The ECCN number structure tells you what the code itself means.
2. License Requirements: the reasons for control
This section lists the reasons for control and where they apply. Each line names a control (for example NS applies to entire entry, MT applies to 7A001.a.1, AT applies to entire entry) and the Country Chart column to check (NS Column 1, AT Column 1). The reasons can differ between paragraphs of the same entry, which is why your classification should name the paragraph.
| Code | Reason for control |
|---|---|
| NS | National security |
| MT | Missile technology |
| NP | Nuclear nonproliferation |
| CB | Chemical and biological weapons |
| RS | Regional stability |
| CC | Crime control |
| AT | Anti-terrorism |
| UN | United Nations embargo |
| EI | Encryption items |
| SL | Surreptitious listening |
| FC | Firearms convention |
With the reasons and the destination, the Commerce Country Chart tells you whether a licence is required. Each code is covered in reasons for control explained.
3. Reporting requirements and control notes
Some entries carry reporting requirements or control notes, for example special provisions for items destined to certain countries. Read them. They can change the licence picture without changing the classification.
4. Licence exceptions the entry allows
The List Based License Exceptions section names the licence exceptions available for the entry: LVS (limited value shipments, with a value limit), GBS (shipments to Country Group B), TSR (technology and software under restriction) and, for some entries, STA (Strategic Trade Authorization) eligibility. Other exceptions in Part 740, such as TMP or ENC, may apply by their own terms. See License Exceptions TMP, STA and GOV and the overview of EAR license exceptions.
5. Related controls, definitions and the Items paragraphs
The List of Items Controlled is the core of the entry, and it has three parts.
| Part | What it contains |
|---|---|
| Related Controls | Pointers to other entries or regulations (the USML, a 600 series entry, a 9x515 entry) that may control similar items. Check them before concluding. |
| Related Definitions | Definitions specific to the entry, alongside the general definitions in Part 772. Words in quotation marks in the CCL are defined terms. |
| Items | The paragraphs, often nested (a, a.1, a.1.a), with the technical parameters. This is what classifies the item. |
6. Notes and technical notes
Notes inside the Items section add exclusions ("5A001.b.5 does not control…"), clarifications and measurement methods. A technical note may define exactly how a parameter is measured, for example how to calculate processing performance, and the comparison has to be made that way. Skipping notes is one of the most common classification mistakes.
Reading an ECCN entry: a worked example
Take a digitally controlled radio receiver with 2,000 channels, a channel switching time of 0.5 ms, automatic scanning and signal identification. Under 5A001, paragraph b.5 covers receivers having all of the following: more than 1,000 channels, a switching time under 1 ms, automatic searching or scanning, and identification of the received signals.
The receiver meets every limb, so the classification is 5A001.b.5, once you have confirmed that no note excludes it (for example equipment specially designed for civil cellular systems). With 800 channels it would not meet b.5, and you would look further, possibly at 5A991.
Defined terms and other common pitfalls
Words in double quotation marks in the CCL, such as "specially designed", "technology", "development", "production", "use" and "space-qualified", are defined in Part 772. Words in single quotation marks are defined in the entry itself, usually in a technical note. The definitions are often narrower than the everyday meaning. "Use" in the EAR, for example, means operation, installation, maintenance, repair, overhaul and refurbishing together. Read the definition before applying a paragraph.
Parts and components are caught by "specially designed" only if they meet the two-step test in § 772.1 (see the specially designed definition). Three more errors come up often:
- A paragraph that requires all of several characteristics is not met by an item that has only one of them.
- "Exceeding" and "equal to or more than" are different comparisons at the boundary.
- Units have to be converted before comparing: kelvin vs. Celsius, TOPS vs. TPP, micro-g vs. ppm.
Checklist for one entry
- Is the item in the entry's category and product group?
- Do the Related Controls point to the USML, a 600 series entry or 9x515 first?
- Which Items paragraph might describe it, and does it meet every required limb?
- Do any notes exclude it, or any technical notes change how a value is measured?
- Which reasons for control apply to that paragraph, and which Country Chart columns?
- Which licence exceptions does the entry allow?
- If no paragraph fits, which 9xx entry should be checked next?
Where to read the current text
The eCFR publishes the current CCL, updated as rules take effect, and BIS also publishes each category as a PDF. The CCL changes several times a year, so note the date of the version you used in your classification record. To search the list for candidate entries, see ECCN lookup.
Reading entries in ECCN.help
ECCN.help's Quick Search opens any entry by code or keyword. In the ECCN.help Classification Workflow, each question is taken from an entry's paragraphs, notes and definitions. When you give figures, the tool compares them with the paragraph's parameters, with units converted, and marks the paragraph your item meets.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.