Helpful Resource for Export Control Determinations
By: Jean Schtokal
A best practice for companies that export is development of an export control classification matrix for their products and services. The matrix should list the item or service (including internal product number, if applicable) and the classification for export purposes (which for example may be an ECCN number, an ITAR Category and subparagraph or a license exception). This internal company document should also include the date the classification was last reviewed (since export control regulations do change and have recently changed) and the person at the company who made the classification (in case follow up is required). If a classification request or commodity jurisdiction request was made to the U.S. government to formally determine the classification, that should be indicated.
While it’s no substitute for digging into the export control regulations, one way to start is the following link to the U.S. Department of Commerce Bureau of Industry and Security webpage, which provides an alphabetical index to the Commerce Control List: http://1.usa.gov/1hVQCCJ. Follow this link and find the button on the left side of the screen that says “Commerce Control List Index.” Note, the index is not an exhaustive list of items controlled for export by the U.S. government. In addition, it does not include items, services or technology covered by other export control regulations, such as those overseen by the U.S. State Department and commonly known as “ITAR.” Please also note that the list is long – don’t print it. It is updated from time to time and is meant to be a starting point for your deep dive into export control regulation, classification for export purposes, and the development of your export compliance program.