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If you run a business exporting products from the US, you likely have at least a passing familiarity with the Export Administration Regulations (EAR). If those regulations require a license to export a product, you'll first need to find the Export Control Classification Number (ECCN) for that product. Licenses are typically required for products that have both commercial and military applications. These licenses are issued by the Commerce Department's Bureau of Industry and Security (BIS), which is also responsible for classifying dual-use products and assigning ECCNs. If the products you're exporting were manufactured by another country, the easiest way to find the ECCN is to contact the original manufacturer. If that isn't an option, you can classify it yourself using the Commerce Control List (CCL) or requesting a commodity classification ruling from the BIS.
Steps
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Identify the original manufacturer or producer of the product. If you purchased a product wholesale that was manufactured by another company and intend to export it, the product likely already has an ECCN assigned to it. Look on the packaging of the product, your invoices, or the product itself to find the name of the original manufacturer of the product.
- While other exporters may also know the ECCN for the product, it's typically best to seek out this information from the original manufacturer, which likely has a database of ECCNs for all of its products.
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Visit the manufacturer's website to find the ECCN. Companies that produce products that are frequently exported and subject to licensing typically have a database or ECCN index on the corporate website. You can search the database using the name or part number of the product. [1] X Research source
- For example, if you needed to find an ECCN for an HP product, you can search on the HP Part Classification Lookup engine for the part number. Since the ECCN may be affected by the country to which you're shipping the part, you would also select the name of the destination country.
- Some manufacturers may require you to have an account to look up ECCNs. For example, Honeywell has an ECCN Part Lookup Tool for its aerospace division, but you must have a purchase account to access the tool. [2] X Research source
Tip: Make sure you're on the corporate or wholesale site, rather than the company's retail site, if the company also sells its products to retail consumers.
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Contact the manufacturer if the ECCN isn't listed online. Smaller companies may not have their databases or ECCN indexes available online. Use the contact information you have for the manufacturer to call and ask for the ECCN for the product you have.
- Before you call, make sure you have all the necessary information for the product, such as the manufacturer's official name for the product, the part number, or the serial number.
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Identify the appropriate CCL category for your product. The CCL organizes all ECCNs into 10 broad categories. Evaluate the general characteristics of your product to decide which category your product falls into. The 10 categories are:
- 0: Nuclear Materials, Facilities, and Equipment
- 1: Materials, Chemicals, Microorganisms, and Toxins
- 2: Materials Processing
- 3: Electronics
- 4: Computers
- 5: Telecommunications and Information Security
- 6: Sensors
- 7: Navigation and Avionics
- 8: Marine
- 9: Propulsion Systems, Space Vehicles and Related Equipment
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Choose which product group your item falls into. Each category is further subdivided into 5 groups. The groups are the same for every category. The number for the category and letter for the group are the first 2 characters of the ECCN. The 5 product groups are: [3] X Research source
- A: Systems, Equipment, and Components
- B: Test, Inspection, and Production Equipment
- C: Material
- D: Software
- E: Technology
Example: An ECCN that started "5D" would be in category 5, telecommunications and information security, and group D, software. The product would, therefore, be some sort of telecommunications software.
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Search the CCL for your product. The CCL is available at https://www.ecfr.gov/cgi-bin/text-idx?node=15:2.1.3.4.45&rgn=div5#ap15.2.774_12.1 . Scroll through the list until you find the category and group you've chosen for your product, then read through the products listed until you find a match. [4] X Research source
- For example, suppose you're exporting demolition blocks and detonators for construction projects. The CCL lists "0A604" as "Commodities related to military explosive devices and charges," which includes your product. Therefore, the ECCN for your product would be 0A604.
- The last 3 numerical digits identify the reasons the export of the product should be controlled. As an exporter, it isn't necessary for you to understand the significance of these numbers.
- Once you've found your product on the CCL, read the "License Requirements" section to find out if a license is required.
Tip: Because the CCL located within the Electronic Code of Federal Regulations (e-CFR) isn't searchable, this process can be cumbersome. Avant International maintains a searchable CCL database that you can download from the company's website.
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Check the license exemptions to confirm your product isn't exempted. Specific exemptions are listed in Part 740, available at https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title15/15cfr740_main_02.tpl . Exemptions typically relate to who's receiving your products and what they intend to do with them. [5] X Research source
- For example, if you're exporting products that normally require a license as a humanitarian donation to a nonprofit organization, your products would be exempt from the licensing requirement.
- Also check the country chart, included in Part 740 as "Supplement 1." Even exempt products may require a license before you can export them to particular countries, as shown in the chart.
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Gather documents or brochures related to your product. When you request a commodity classification from the BIS, you can attach any supporting documents or information you believe would help the licensing officer who processes your request better understand your product. Documents such as product specifications, marketing brochures, and patent applications can help the licensing officer determine how to classify your product.
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Register for the SNAP-R service. Go to https://snapr.bis.doc.gov to sign up for a SNAP-R account. You'll need a valid email address to activate your registration. After you've registered, the BIS will send a confirmation email to the email address you provide. [7] X Research source
- You must click the link in the email within 5 days of receipt to complete your registration. Then, the BIS will assign you a Company Identification Number (CIN). You'll need your CIN to submit documents to the BIS through SNAP-R.
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Complete your application on SNAP-R. Log into your account on SNAP-R and click the link to "Create a Work Item." Then, follow the prompts to complete the BIS-748 multi-purpose application. The system won't allow you to submit the form until all required sections are filled out. [8] X Research source
- Additional instructions on filling out the application are available in the e-CFR at https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title15/15cfr748_main_02.tpl .
- Upload the attachments that you want to include with your request before submitting it. Since attachments aren't required, the system won't prompt you to do this.
Tip: If you submit your request and forget to add your attachments, contact the licensing officer processing your application and ask to have it returned without action. Then you can resubmit it with the correct attachments.
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Track the status of your application through SNAP-R. Once you've submitted your request, your SNAP-R account updates the "Work Item" you created with its status. If the licensing officer needs to contact you, they'll send you a message through your SNAP-R account. [9] X Research source
- Classification requests are typically processed within 3 to 4 weeks. However, more complex requests or requests for multiple products may take longer.
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Tips
- If your product has an ECCN, apply for a license using the SNAP-R service on the BIS website. BIS stopped processing paper license applications in 2008. [10] X Research sourceThanks
- If you need assistance finding an ECCN or applying for a license, call the BIS Export Counseling Service at 202-482-4811.Thanks
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References
- ↑ https://www.cisco.com/c/en/us/about/legal/global-export-trade/strategic-product-group.html
- ↑ https://aerospace.honeywell.com/en/learn/about-us/about-myaerospace
- ↑ https://www.bis.doc.gov/index.php/regulations/commerce-control-list-ccl
- ↑ https://www.bis.doc.gov/index.php/regulations/commerce-control-list-ccl
- ↑ https://www.bis.doc.gov/index.php/regulations/commerce-control-list-ccl
- ↑ https://snapr.bis.doc.gov/snapr/docs/fieldHelp.html
- ↑ https://snapr.bis.doc.gov/snapr/docs/fieldHelp.html
- ↑ https://snapr.bis.doc.gov/snapr/docs/fieldHelp.html
- ↑ https://snapr.bis.doc.gov/snapr/docs/fieldHelp.html
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