ECCN Lookup: Step-by-Step Classification Guide

BIS processed over 34,000 export license applications in 2025, with 23% returned for incorrect or incomplete classification (BIS.gov annual report). One in four. Bounced back before anyone even looks at the actual export question. The classification determines everything—whether you need a license, which destinations are off-limits, what exceptions might apply. Get the ECCN wrong and you've built your entire export compliance program on sand.

Key Takeaways

• ECCN lookup is your responsibility as the exporter, not BIS or your freight forwarder; self-classification is the default (15 CFR 730.7)
• The Commerce Control List contains roughly 2,500 entries across 10 categories and 5 product groups; finding the right entry means matching technical specs, not product descriptions
• Most commercial items end up as EAR99 (subject to EAR but not specifically controlled), but assuming EAR99 without doing the work is the single most common classification mistake we see
• Documentation of your classification reasoning matters almost as much as the classification itself—BIS wants to see how you got there

Understanding ECCN Structure

An Export Control Classification Number looks like this: 3A001. Not random. Every character tells you something, and once you understand the structure, lookup gets way faster.

First digit is the category—what type of item:

• 0: Nuclear materials, facilities, equipment
• 1: Special materials and related equipment
• 2: Materials processing
• 3: Electronics
• 4: Computers
• 5: Telecommunications and information security
• 6: Sensors and lasers
• 7: Navigation and avionics
• 8: Marine
• 9: Aerospace and propulsion

The letter indicates product group:

• A: Systems, equipment, components
• B: Test, inspection, production equipment
• C: Materials
• D: Software
• E: Technology

Last three digits identify the specific entry. So 3A001 means electronics (3), systems/equipment/components (A), entry 001.

Here's where people trip up: CCL entries don't describe commercial products. They describe technical capabilities and parameters. Entry 3A001 doesn't say "oscilloscopes." It describes performance characteristics that certain oscilloscopes might meet. Your job is matching your product's actual technical specs against those regulatory parameters. Totally different mental model than browsing a product catalog.

Step 1: Gather Technical Documentation

Before you touch the CCL, pull together everything you know about your product. And we do mean everything.

Technical specifications from the manufacturer. Not the marketing brochure—the actual engineering specs. Data sheets, technical manuals, test reports. You need precise numbers: frequencies, speeds, accuracies, capacities, tolerances. Vague descriptions won't cut it when BIS comes asking.

Component information matters too. Lots of controlled items are controlled because of what's inside them, not what they look like from outside. Embedded encryption chips, precision components, controlled materials—these drive classification even when the finished product seems totally ordinary. We once spent three weeks helping a client figure out why their "simple" industrial sensor needed a license. Turned out there was a controlled accelerometer buried in the assembly that nobody had thought to mention.

Intended use documentation. Some ECCNs control items "specially designed" for particular applications. You need to know—and be able to show—what the item was designed to do.

We've watched companies classify products based on catalog descriptions and marketing copy. Then BIS asks for technical substantiation and there's nothing. No specs, no analysis, no paper trail. That's when things get expensive. Start with the documentation.

Step 2: Determine Jurisdiction

Not everything falls under EAR. Before spending hours on ECCN lookup, make sure your item is actually subject to Export Administration Regulations.

Items controlled under ITAR (International Traffic in Arms Regulations) don't get ECCNs—they have USML categories. If your item was specifically designed for military applications and appears on the US Munitions List, you're dealing with State Department, not Commerce. Completely different regime, completely different headaches.

Items outside US jurisdiction don't need ECCNs either. Foreign-made items that never touched the US, contain minimal US-origin content, and aren't controlled for US-origin technology generally aren't EAR-controlled.

Most commercial items are EAR-subject. But confirming that is step one before you do anything else.

Step 3: Work Through the CCL Systematically

Now you're actually in the Commerce Control List. Available at BIS.gov, updated regularly. Here's how we approach it after years of doing this:

Start with the category matching your product type. Electronics? Category 3. Software? Probably 4D or 5D. Chemicals? Category 1C. Don't browse randomly—narrow down first.

Read the category-level notes. Each category has introductory notes explaining scope, definitions, exclusions. These notes matter more than people realize. An item might look like it belongs in Category 3, but the notes clarify it's actually covered somewhere else. Skip the notes and you'll waste hours in the wrong section.

Work through relevant entries in order. Don't jump to what looks like the right answer. Entries have hierarchical relationships—specific entries typically take precedence over general ones. Missing a specific entry because you stopped at the general one is embarrassingly common. We've made this mistake ourselves early on. Cost us a weekend fixing a client's classification matrix.

Match technical parameters exactly. Here's where classification actually fails most of the time. The CCL describes performance thresholds: frequencies, accuracies, bit lengths, processing speeds. Your product specs have to exceed the control threshold to be captured by that entry.

Say your oscilloscope has 500 MHz bandwidth. Entry 3A002.a.1 controls oscilloscopes exceeding 1 GHz bandwidth. Your product doesn't meet the threshold—not controlled under that entry. But you need to check every relevant parameter against every relevant entry. One parameter exceeding one threshold in one entry means the item is controlled. Miss one and you've misclassified.

Step 4: Evaluate EAR99

If you've worked through every potentially relevant CCL entry and your item doesn't match any of them, it's probably EAR99. This means: subject to EAR, but not specifically controlled on the CCL.

EAR99 isn't a free pass. You still can't export EAR99 items to embargoed destinations without authorization. You still can't ship to denied parties. End-use and end-user restrictions still apply.

But EAR99 items generally don't require licenses for most destinations and don't trigger the specific controls that CCL-listed items face.

The dangerous assumption: "It's probably EAR99." We've seen this assumption destroy companies. They assume without documenting the analysis, ship for years, then BIS asks why a clearly controlled item went out without licenses. The assumption was wrong. The documentation didn't exist. The penalties ran into seven figures. One company we talked to had been shipping controlled encryption equipment as EAR99 for four years. Four years of unlicensed exports. That conversation wasn't fun for anyone.

Document your EAR99 determination. Show which CCL entries you evaluated. Explain why each one didn't apply. Create a record proving you actually did the analysis.

Step 5: Check Reason Codes and License Exceptions

Every CCL entry includes "Reason for Control" codes: NS (national security), MT (missile technology), NP (nuclear nonproliferation), CB (chemical/biological), AT (antiterrorism), and others.

These codes determine license requirements by destination. An item controlled only for AT reasons faces different restrictions than an item controlled for NS reasons. The Commerce Country Chart (Supplement No. 1 to Part 738) cross-references these codes against destination countries to show where licenses are required.

License exceptions can eliminate the need for individual export licenses even when an item is controlled. Common ones:

TMP — Temporary exports and re-exports RPL — Servicing and replacement parts GOV — Government agencies and international organizations TSR — Technology and software under restriction ENC — Encryption commodities and software

Each exception has specific eligibility requirements. Don't assume one applies—verify your transaction meets every condition. We've seen companies claim exceptions they didn't actually qualify for. BIS noticed. BIS always notices eventually.

Step 6: Document Everything

Classification isn't done until it's documented. We cannot stress this enough.

Your classification record should include:

Product identification. Part numbers, model numbers, version numbers. Specific enough that the classification clearly applies to this item, not just a product family.

Technical specifications. The actual parameters you evaluated. Not "high-speed processor" but "3.2 GHz clock speed, 8-core architecture."

CCL entries evaluated. Every entry you considered, why you considered it, why the product did or didn't meet control parameters.

Classification conclusion. The ECCN (or EAR99 determination) with clear reasoning connecting specs to regulatory thresholds.

Classifier and date. Who made this determination and when. Names matter.

Source documents. References to the technical documentation you used.

When BIS reviews your exports—and at some point they might—they want to see this analysis. A defensible classification shows you understood the process, applied it correctly, and can reproduce your reasoning years later. "We thought it was EAR99" doesn't cut it.

Common Mistakes We See

Relying on supplier classifications. Your supplier classified their product for their exports. That classification might be wrong. Might also be right for their product but wrong for yours if you've modified anything. Self-classification means you verify independently.

Matching product names instead of specifications. The CCL doesn't control "cameras" or "computers." It controls items meeting specific technical parameters. A camera is EAR99 unless its specs hit controlled thresholds. Product names mean nothing.

Stopping at the first match. CCL entries overlap. A more specific entry might provide different treatment—often less restrictive—than a general one. Work through all possibilities before concluding.

Ignoring software and technology. Export technical data about a controlled item—drawings, specs, production know-how—and that technology may be separately controlled. The ECCN for the hardware and the ECCN for technology about the hardware can differ. We've seen companies nail product classification then completely miss the technology controls. Happened to a client shipping machine tools—perfect hardware classification, zero attention to the CAD files going along with them.

Failing to reclassify after changes. Product updates, new components, feature additions—anything affecting technical parameters can change classification. Your old classification doesn't automatically carry over to the new model.

When to Request Official Classification

BIS offers formal commodity classification via SNAP-R. You submit product information, BIS evaluates, provides an official ECCN determination. Takes 30-60 days typically.

Official classification makes sense when the item sits right at control thresholds and you're genuinely uncertain. Or when export value justifies the wait. Or when you need BIS's stamp for a big customer.

Official classification doesn't make sense when classification is obvious, when you can't wait a month or two, or when you're unwilling to accept whatever BIS decides. Fair warning: BIS might classify more restrictively than you expected. Once you have an official determination, you're stuck with it.

FAQ

Who is responsible for ECCN classification?

The exporter. Period. Not BIS, not your freight forwarder, not your customer. You can hire help, but legal responsibility stays with you. Self-classification is the EAR default (15 CFR 730.7).

How often should we reclassify products?

Whenever specs change, whenever CCL updates (check quarterly minimum), whenever you're entering new markets triggering different restrictions. Annual review of your full product catalog is reasonable practice for most companies.

Can we use our supplier's ECCN?

As a starting point for your own analysis, sure. As your final classification without independent verification, absolutely not. Your supplier classified their product for their situation. Your product might differ. Your responsibility remains.

What if we get it wrong?

Voluntary self-disclosure to BIS if you discover errors that resulted in unlicensed exports. Penalties vary, but disclosure typically reduces them substantially. Fix forward—reclassify correctly and implement better procedures.

Classification accuracy drives everything downstream—license requirements, destination restrictions, exception eligibility. Getting it wrong cascades into enforcement problems that cost far more than the time spent getting it right. Platforms like Lenzo surface ECCN alongside HS codes and destination controls, connecting product classification to the practical export decisions that follow. That integration matters when a single classification error can unravel years of shipments.