# Export Codes: EAR99 or ECCN for every product you ship abroad, with the reason and the AES filing codes.

> Every item subject to US export rules is either EAR99 or has an Export Control Classification Number, and that decides whether you need a license and what goes into your export filing. Export Codes reviews your catalog against the Commerce Control List, gives each product a proposed classification with the reasoning, and maps it to the codes your AES filing needs.

- Page: https://rotomal.com/eccn-classification/
- Category: Customs and trade documents
- Language: en
- Billing: one-time payment
- From: $19 one-time
- Request (free, no card): https://rotomal.com/eccn-classification/request/

- Each product with a proposed EAR99 or ECCN, the Commerce Control List entry and technical parameter it was checked against, and the documents used.
- Products where the manufacturer already publishes an ECCN are matched to it first; gaps are worked out by self-classification following BIS's order of review.
- For each product, the license code to report in the Electronic Export Information, such as NLR with code C33 for EAR99, and when an EEI filing is required at all.

## Export classification is easy to skip until a shipment or buyer asks for it

Small hardware and electronics sellers usually know their HTS code for imports and nothing about export classification. Then a distributor abroad asks for the ECCN, a freight forwarder wants the license code for the export filing, or an order arrives from a country that triggers extra rules. The answer depends on the product's technical parameters, not its price or its tariff code.

Most products turn out to be EAR99: subject to the Export Administration Regulations but not listed on the Commerce Control List. EAR99 items usually ship without a license, but not to every buyer or destination. Items on the list, such as some networking gear, sensors, lasers or encryption products, may need a license or a license exception, and their ECCN must be reported in certain export filings, including all shipments of listed items to China, Russia or Venezuela regardless of value.

BIS lets exporters self-classify, but it expects a technical understanding of the item and familiarity with the structure of the list. For a team of five shipping 60 products, reading Category 3 and Category 5 parameters against every datasheet is the work that never gets done.

- BIS says an item can be classified in three ways: by asking the manufacturer, producer or developer for its ECCN, by self-classification using the order of review in Supplement No. 4 to Part 774 and BIS tools, or by requesting an official BIS classification through SNAP-R under section 748.3 of the EAR. (source: https://www.bis.gov/licensing/classify-your-item)
- BIS defines EAR99 as items subject to the EAR but not described in any ECCN; they generally need no license, but may need one for a prohibited or restricted end user, end use or destination. (source: https://www.bis.gov/licensing/classify-your-item)
- BIS explains that an ECCN is a five-character code whose first digit (0 to 9) is the category and second character (A to E) the product group, that ECCNs are unrelated to Schedule B or HTS codes, and that classifications should be re-checked against the current Commerce Control List because ECCNs change. (source: https://www.bis.gov/licensing/classify-your-item)
- Under 15 CFR 758.1, EEI must be filed in AES in several cases, including exports needing a license, listed (CCL) items to China, Russia or Venezuela regardless of value, shipments to Country Group E:1 or E:2, and goods over $2,500 per Schedule B number unless an FTR exemption applies; EAR99 items shipped without a license use NLR with code C33. (source: https://www.law.cornell.edu/cfr/text/15/758.1)

## How it works

1. **$19 5-product check.** Send five products with datasheets. Within two business days we tell you which look like EAR99 and which need a closer look against the list.
2. **You send the catalog.** Product list, datasheets, manuals and any ECCNs your suppliers or chip and module makers already publish.
3. **We classify.** Manufacturer ECCNs matched first, the rest self-classified following BIS's order of review, each with written reasoning, in up to 5 business days.
4. **You review and use it.** You check and adopt the classifications, give the sheet to your forwarder, and request an official BIS classification for any product you want confirmed.

## Features

- **Classification sheet.** Product, proposed EAR99 or ECCN, the list entry and parameter checked, the reasoning and the source documents. Excel and CSV.
- **Manufacturer ECCN match.** Where a component or finished product's maker publishes an ECCN, we record it with the link, and note whether your product changes anything that matters.
- **AES filing codes.** For each product, the license code to report in the EEI when shipping without a license, and whether the ECCN must be entered for that destination.
- **EEI trigger guide.** A one-page summary of 15 CFR 758.1 for your team: when an AES filing is required, such as over $2,500 per Schedule B number, any license, or listed items to China, Russia or Venezuela.
- **Flags for closer review.** Encryption functions, high-performance parameters, military or space use and other cases where an official BIS classification or an export lawyer is the safer route.
- **Re-check date.** Each classification is dated against the Commerce Control List version used, so you know when to re-check after BIS changes the list.

## Who it's for

- **Small electronics and IoT brands.** You sell boards, sensors, smart devices or accessories abroad. You get an ECCN or EAR99 for each product, with reasoning a distributor will accept.
- **Hardware and tool sellers.** Most of your catalog is probably EAR99, but you are not sure about every item. You get a checked sheet instead of a guess.
- **Online sellers starting to export.** International orders are growing and your forwarder wants filing codes. You get the codes and a plain rule sheet for when EEI is needed.
- **Startups answering buyer questionnaires.** A large customer's compliance team wants ECCNs before onboarding you. You get them, documented, in days.

## Works with

BIS Commerce Control List (15 CFR Part 774), BIS Interactive Commerce Control List, Manufacturer and component ECCN listings, Product datasheets and manuals (PDF), Shopify or WooCommerce product exports, Excel and CSV, Your freight forwarder's export template

## Pricing

One-time prices, paid once after the quick check. The $19 quick check is credited in full against a Catalog pass or Catalog Plus ordered within 30 days. A product is one model; variants that differ only in colour or size count once. Classifications are our proposal with written reasoning; you decide what to adopt and remain responsible for your exports. We do not file EEI, apply for licenses or submit requests to BIS for you. Founding customer pricing applies to early-access orders.

| Plan | Price | Includes |
| --- | --- | --- |
| Quick check | $19 one-time | Likely EAR99 or needs review; Manufacturer ECCNs found; What documents we would need; Reply within two business days; The $19 is credited in full against a Catalog pass or Catalog Plus ordered within 30 days |
| Catalog pass | $149 one-time | Classification sheet with reasoning; Manufacturer ECCN match; AES filing codes per product; EEI trigger guide; Flags for closer review; Re-check date per product |
| Catalog Plus | $390 one-time | Everything in Catalog pass; Draft product descriptions for an official BIS request; New products added at no cost for 90 days; One re-check after a BIS list change within 12 months; Email help for 90 days |

## Compared with the alternatives

- **Asking the manufacturer or self-classifying.** Free, and BIS's own first suggestions. It works well when your suppliers publish ECCNs and your products are simple. Export Codes starts there too, and fills the gaps.
- **An official BIS classification.** You can ask BIS to classify an item through SNAP-R under section 748.3 of the EAR. It gives the most certainty and is worth it for borderline products; it takes longer than an internal review.
- **Compliance consultants.** Consultants classify per product. TecEx Global Compliance, for example, lists HS code reviews from $40 per product, with an ECCN assessment as a separately priced add-on. Export lawyers are the right call for licenses and anything with military, space or high-end encryption content.

## Security and data

- Datasheets and product files are encrypted in transit and at rest and used only for your classification.
- We do not accept controlled technical data or source code; send public datasheets and manuals only.
- Only the people working on your order can open your files, and each access is logged.
- Files are deleted 60 days after delivery, or sooner on request.

## From request to a classification sheet

Catalog passes are delivered within 5 business days of receiving complete datasheets.

- Day 1: Quick check on 5 products.
- Day 1–2: You send the catalog, datasheets and any supplier ECCNs.
- Day 3–5: Classification sheet, AES filing codes and the EEI trigger guide delivered.
- After delivery: You review, adopt and share with your forwarder; we answer questions.

## FAQ

### What is the difference between EAR99 and an ECCN?

An ECCN means the item is described on the Commerce Control List and may need a license depending on destination and reason for control. EAR99 means the item is subject to the EAR but not on the list; it usually ships without a license, except to prohibited end users, end uses or destinations.

### Can I classify my own products?

Yes. BIS allows self-classification and expects a technical understanding of the item and familiarity with the list. You can also ask the manufacturer for its ECCN or request an official classification from BIS.

### Is the ECCN the same as my HTS or Schedule B code?

No. BIS says ECCNs are unrelated to Schedule B and HTS codes. You need both: the Schedule B or HTS code for statistics and duties, the ECCN or EAR99 for export controls.

### When do I have to file EEI in AES?

Among other cases: when a license is required, when listed items go to China, Russia or Venezuela regardless of value, for shipments to Country Group E:1 or E:2 destinations, and when goods under one Schedule B number are worth more than $2,500, unless an FTR exemption applies.

### What do I put in the EEI for an EAR99 product?

Shipped without a license, an EAR99 item is reported as NLR with the FTR code C33. For listed items shipped NLR, the ECCN is also entered when the reason for control is not only anti-terrorism, and always for China, Russia or Venezuela.

### Does EAR99 mean I can ship anywhere?

No. A license may still be needed for prohibited or restricted end users, end uses and destinations. Classification is one step; screening the buyer is another.

### Is this legal advice?

No. Export Codes is a classification and documentation service, not legal advice, and Rotomal is not affiliated with BIS or the Census Bureau. For licenses, borderline items or enforcement questions, use an export control lawyer or request an official BIS classification.

## Guides

- [How to find the ECCN for your product](https://rotomal.com/eccn-classification/how-to-find-eccn/): How to classify a product under the EAR: ask the manufacturer, self-classify with the Commerce Control List, or ask BIS. EAR99 vs ECCN and what goes into AES.

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Rotomal · https://rotomal.com/eccn-classification/ · hello@rotomal.com