Anatomy of an ECCN Entry
Every ECCN entry on the Commerce Control List follows a standardized format prescribed by BIS. Understanding each component is essential for accurate classification. An entry includes the ECCN code, heading, license requirements, license exceptions, list of items controlled, and technical notes.
The heading provides a brief description of what the ECCN covers. Below the heading, you will find specific paragraphs (designated by lowercase letters and numbers) that describe controlled items in precise technical detail.
Control Parameters and Thresholds
Many ECCNs include quantitative thresholds that determine whether an item falls within scope. These thresholds might specify processing speed (measured in TOPS or TFLOPS), frequency ranges, accuracy levels (in CEP or arcseconds), wavelength ranges, power output, or key lengths for encryption.
Items that fall below all specified thresholds are generally not controlled under that ECCN and may either fall under a lower-control ECCN or be classified as EAR99. The 'below threshold' fallback ECCN is often indicated in notes accompanying the entry.
License Requirements and Reasons for Control
Each ECCN lists its Reasons for Control, which may include National Security (NS), Missile Technology (MT), Nuclear Nonproliferation (NP), Chemical and Biological Weapons (CB), Anti-Terrorism (AT), Regional Stability (RS), or other reasons. The reason for control determines which countries require licenses by referencing the Country Chart in Supplement No. 1 to Part 738.
License exceptions that may apply are also listed in each ECCN entry. Common exceptions include TMP (temporary exports), STA (Strategic Trade Authorization), and ENC (encryption items).