The ECCN product group is the second character of every ECCN, a letter from A to E. Under the EAR, the five CCL product groups are A (systems, equipment and components), B (test, inspection and production equipment), C (materials), D (software) and E (technology). The group says what kind of thing the item is, and it is fixed by what you are actually exporting. The same technology area has an A entry for the hardware, a D entry for its software and an E entry for the know-how, each with its own parameters and controls.
What are the five CCL product groups?
The letter sits between the category digit and the entry number, as in 3A001 (see ECCN number structure explained). Here is what each group holds.
A: systems, equipment and components
Finished products, equipment, assemblies, parts, components, accessories and attachments. Most physical products fall here: accelerometers (7A001), cameras (6A003), encryption appliances (5A002), servers (4A003, 4A994), bearings (2A001, 2A991).
Parts and components are in group A as well. Whether a particular part is controlled usually depends on two things: whether the entry names it (for example "specially designed components therefor"), and whether it passes the "specially designed" test in § 772.1. A standard fastener in a controlled machine is usually released. A custom sensor head designed only for that machine may be caught in the same entry as the machine. See the specially designed definition.
B: test, inspection and production equipment
Equipment used to make, test or inspect controlled items: semiconductor manufacturing tools (3B001), telecommunications test equipment (5B991), encryption production equipment (5B002), radar cross-section measurement systems (6B008). Ask what the equipment is designed to produce or test.
C: materials
Raw and processed materials: composites and fibres, specialised alloys, chemicals, photoresists (3C992), optical fibres (6C992), biological agents (1C351). Many materials entries turn on precise physical or chemical properties.
D: software
Software specially designed or modified for the development, production or use of controlled items (4D001, 3D001), and software that itself performs a controlled function. Encryption software is 5D002 or, if it qualifies as mass market, 5D992. A software package exported on its own is classified in group D, even if the hardware it runs on is in group A.
How the software travels affects the answer:
- Embedded firmware shipped inside hardware is normally part of the hardware's classification.
- Bundled software on media shipped with the hardware is generally treated with the hardware, but check the entry.
- Standalone software is classified on its own in group D. That includes software sold separately, downloads, updates, development kits and development tools.
- Source code may be classified as software or, in some cases, as technology. Published open-source code may be outside the EAR; see open-source encryption and the EAR.
E: technology
"Technology" under the EAR means specific information necessary for the development, production or use of an item. It covers technical data (blueprints, formulae, engineering designs, drawings, specifications, manuals, process know-how) and technical assistance. Examples are 3E001 (technology for Category 3 items), 4E001 and 5E002 (encryption technology). Production drawings are E. A user manual that is publicly available may be outside the EAR as published information.
Information that is published, meaning freely available to the public, is outside the EAR under Part 734, as are the results of fundamental research. General scientific principles and basic marketing information are not "technology".
Technology can be exported without shipping anything: in an email, during a visit, or by showing data to a foreign national in the United States, which is a "deemed export" (see deemed exports). Because it can leave by conversation as well as by file, technology is often the hardest group to classify.
How to choose the right ECCN product group
Start from what you are actually shipping.
| What you export | Product group |
|---|---|
| A device or piece of equipment | A |
| Test, inspection or production equipment | B |
| A material | C |
| Code, such as a file of executable code, a download or an update | D |
| Drawings, know-how or technical assistance | E |
The groups never mix: software cannot sit in A, and technology cannot sit in D. The product group narrows the search after you have chosen one of the ten CCL categories. The full method is in how to find the ECCN for your product.
One technology area across the groups: encryption
| Item | ECCN |
|---|---|
| A network encryption appliance | 5A002 (or 5A992.c if mass market) |
| Equipment for producing encryption appliances | 5B002 |
| Development software for those appliances | 5D002.a |
| Design know-how for them | 5E002.a |
See encryption export controls explained for how these entries work.
Product groups in ECCN.help
In the ECCN.help Classification Workflow, what you are classifying (a physical product, software or technology) decides the product group automatically. Software goes to group D and technology to E, and the tool will not offer an entry from the wrong group. Only physical products are asked to choose between A, B and C.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.