ECCN & Export Control Guide: Compliance Essentials

Export controls regulate what products can be shipped internationally and to whom. Non-compliance can result in severe penalties.

Understanding Export Controls

What Are Export Controls?

Regulations that:

Restrict certain exports
Control technology transfers
Limit transactions with certain parties
Protect national security

Key Regulatory Bodies

Agency	Jurisdiction
BIS (Bureau of Industry and Security)	Commercial items (EAR)
DDTC (Directorate of Defense Trade Controls)	Military items (ITAR)
OFAC (Office of Foreign Assets Control)	Sanctions
Nuclear Regulatory Commission	Nuclear materials

ECCN Explained

What Is ECCN?

Export Control Classification Number: A 5-character code that identifies items subject to export controls.

Format: 0A001

First character: Category (0-9)
Second character: Product group (A-E)
Last 3 digits: Control reason

ECCN Categories

Category	Description
0	Nuclear & Miscellaneous
1	Materials, Chemicals
2	Materials Processing
3	Electronics
4	Computers
5	Telecommunications, Security
6	Sensors, Lasers
7	Navigation, Avionics
8	Marine
9	Aerospace, Propulsion

Product Groups

Code	Type
A	Equipment, assemblies
B	Test, inspection equipment
C	Materials
D	Software
E	Technology

EAR99: Most Common Classification

What Is EAR99?

Items subject to Export Administration Regulations (EAR) but:

Not on the Commerce Control List
No ECCN assigned
Generally can be exported without license

EAR99 Still Has Restrictions

Cannot ship EAR99 to:

Embargoed countries
Denied parties
Prohibited end uses
Weapons of mass destruction programs

Determining Classification

Self-Classification Steps

Is it subject to EAR?

Made in US?
Contains US-origin content?
Subject to re-export rules?

Check Commerce Control List (CCL)

Match product to ECCN
Review technical parameters

If no ECCN matches: EAR99

Classification Request

When unsure:

File commodity classification request with BIS
14-day average response time
Binding decision

License Requirements

When Is a License Needed?

Factors determining license requirement:

ECCN of the item
Destination country
End user
End use

License Types

Type	Use
No License Required (NLR)	Most EAR99 shipments
License Exception	Meets exception criteria
Specific License	Individual BIS approval

Common License Exceptions

Exception	Code	Use Case
Temporary imports/exports	TMP	Demonstrations
Servicing	RPL	Repairs, parts
Technology & Software	TSR	Certain releases
Consumer communications	CCD	Mass-market items

Denied Party Screening

Who Must Be Screened?

Buyer/consignee
End user
Any intermediary
Financial parties

Screening Lists

List	Maintained By
Entity List	BIS
Denied Persons List	BIS
Unverified List	BIS
SDN List	OFAC
Debarred List	DDTC

Screening Process

For each transaction:
Collect party names and addresses
Screen against all lists
Document results
If match: STOP and investigate
If clear: Proceed with caution

Country Restrictions

Embargoed Countries

Comprehensive sanctions:

Cuba
Iran
North Korea
Syria
Crimea region

Restricted Destinations

Heightened controls:

Russia
Belarus
China (certain items)
Venezuela (certain items)

Red Flags

Warning Signs of Diversion

Red Flag	Example
Unusual customer	New, unknown buyer
Cash payment	Large cash or wire
Delivery request	Unusual forwarding
Vague end use	Can't explain purpose
Technology mismatch	Low-tech country, high-tech product
Refused info	Won't provide end use

If Red Flags Appear

Do not proceed automatically

Ask more questions

Document responses

Escalate if concerns remain

Consider filing voluntary disclosure

Compliance Program

Elements of Export Compliance

Management commitment

Risk assessment

Written procedures

Training

Screening

Recordkeeping (5 years minimum)

Auditing

Corrective action

atoship Export Compliance

Ship confidently with atoship:

Denied party screening: Automated checks

Country restrictions: Flagged at shipping

Documentation: Required export forms

ECCN guidance: Classification resources

Compliance alerts: Regulatory updates

Penalties for Violations

Civil Penalties

Up to $300,000 per violation
Denial of export privileges
Seizure of goods

Criminal Penalties

Up to $1 million per violation
Up to 20 years imprisonment
Both company and individuals liable

Conclusion

Export control compliance is mandatory for international shipments. Understand your ECCN classification, screen all parties, and maintain proper documentation. Use atoship to access compliant international shipping with built-in screening and documentation tools.