What Is EAR99? EAR99 vs. ECCN, NLR, and 'Not Subject to the EAR' (2026)

Hello, this is Ryuta Hamamoto from TIMEWELL.

Short answer first. EAR99 is the classification for items that are subject to the U.S. Export Administration Regulations (EAR) but are not described under any Export Control Classification Number (ECCN) on the Commerce Control List (CCL). The Bureau of Industry and Security (BIS) puts it this way: if your item is subject to the EAR but is not described in or otherwise classified under any ECCN, it is designated EAR99¹. Most EAR99 items are ordinary commercial goods, and in many transactions they ship without a license. But EAR99 sits inside the EAR, not outside it. Destination, end user, and end use can still require a license, and EAR99 is not the same thing as "non-applicable" under Japan's export controls. I re-checked every rule and date in this article against the eCFR and the Federal Register as of October 4, 2026.

That is the textbook version. In practice, "in many transactions" is where the trouble starts. I still hear compliance teams, U.S. exporters and foreign re-exporters alike, say: "The supplier marked it EAR99, so it is outside the regulations." That is wrong. EAR99 is a lane on the EAR road, and destination, counterparty, and end use can still put a license on the table.

The counterparty piece is also in motion this year. The Affiliates Rule (the 50% rule), which extends certain Entity List-style restrictions to entities owned 50 percent or more by listed parties, is currently stayed. The stay runs through November 9, 2026 under the Federal Register notice. The U.S. and China have announced that the arrangement covering the stay will run to January 10, 2027 (stated officially by China's Ministry of Commerce; on the U.S. side, so far only the Treasury Secretary's remarks as reported in the press), but BIS had not published an extension as of October 4². Whichever way it lands, a company that ships nothing but EAR99 items still needs ownership screening on its calendar.

What follows covers how EAR, EAR99, and ECCNs nest; what EAR99 precisely means; how it differs from "not subject to the EAR" and from Japan's "non-applicable"; how to verify a classification; the three situations where EAR99 still needs a license; how to tell EAR99 apart from 99-series ECCNs like 3A991; and how EAR99 parts are treated in a de minimis calculation. If you want a quick read on where your program stands first, the free export compliance self-assessment takes about three minutes.

EAR, EAR99, and ECCN at a Glance

Term	What it means	Position	Item-based license
EAR	Export Administration Regulations, the BIS-administered U.S. export control framework	The whole rule set (15 CFR Parts 730 to 774)	Not a product decision by itself
ECCN	Export Control Classification Number, the five-character code for items listed on the CCL	Inside the EAR; list-controlled items	Determined by ECCN and destination via the Country Chart
EAR99	Catch-all for EAR-subject items that match no ECCN	Inside the EAR; not list-controlled	Generally not required (destination, end user, and end use can still trigger a license)

EAR99 is not "outside the EAR." Think of the EAR as the road. An ECCN is a lane with posted signs. EAR99 is a lane with no speed-limit signs. You are still on the road.

Next, the comparison teams most often get wrong, including "not subject to the EAR."

	EAR99	ECCN-listed (on the CCL)	Not subject to the EAR
Position	Subject to the EAR; catch-all when no ECCN matches	Subject to the EAR; listed with a five-character ECCN	The EAR does not apply at all
Item-based license	Generally not required	Determined by ECCN and destination via the Country Chart	Concept does not exist under the EAR
License still needed when...	Embargoed destinations, restricted end users, end-use concerns	Same, plus item-based controls	None under the EAR (watch ITAR and other regimes)
Typical examples	Ordinary consumer goods, general-purpose office equipment	Advanced semiconductors, certain encryption, controlled machine tools	Published technology, ITAR-controlled defense articles
How to verify	Full CCL Order of Review; confirm no ECCN applies	Supplier confirmation, CCL search, BIS classification request (CCATS)	Check the carve-outs in 15 CFR 734.3(b)

These distinctions are where all EAR work starts.

What EAR99 Is, and How It Differs from "Not Subject to the EAR"

Part 734 of the EAR defines scope first: is the item subject to the EAR at all? Only then do you ask whether it matches an ECCN on the CCL³. If you work through the Order of Review and find no matching ECCN, the item is EAR99. BIS describes EAR99 as a "basket" for items not specified under any CCL entry¹.

In other words, EAR99 is a conclusion you reach after a review, not a default you assume before one. "We have not checked, so it is probably EAR99" is exactly the reasoning that collapses when a misclassification surfaces later.

"Not subject to the EAR" is a different layer. It covers things the EAR does not reach at all: published information available to the public, certain fundamental research results, and defense articles controlled by the State Department under ITAR³. ITAR items sit outside the EAR but inside a stricter regime, so the reassuring sound of "not subject" deserves no comfort if the item's real home is ITAR.

The misunderstanding also runs the other way. "Our product is made outside the United States, so the EAR does not apply" is often false. Foreign-made products that incorporate controlled U.S.-origin content above the de minimis threshold become subject to the EAR, and products made from certain U.S.-origin technology can be captured by the Foreign Direct Product Rule (FDPR). For many non-U.S. manufacturers, this is where EAR99 first shows up: a U.S. supplier answers "this component is EAR99," and the question becomes how that answer feeds into the review of the finished product.

One more point that gets missed: EAR99 is not a permanent label. BIS warns that ECCNs can change over time and asks exporters to check a manufacturer's classification against the current CCL¹. When new entries are added or existing ones broadened, an item that was EAR99 last year can pick up an ECCN. That is why the date on a supplier's answer matters as much as the answer itself.

When I train teams on EAR99, I use the road metaphor. No posted speed limit, but traffic law still applies, meaning the EAR's transaction-based rules on counterparties and end uses. No speed limit does not mean you can run red lights.

A form for recording why you landed on EAR99. We publish a working checklist that walks the same order of review item by item: is it subject to the EAR, does it match an ECCN on the CCL, or does it fall to EAR99. It has fields for recording your CCL review, the embargo, end-use, and end-user checks, de minimis and FDP judgments, and the cross-check against Japan's classification, so a completed sheet doubles as your internal determination record. Download the EAR Classification Flow & EAR99 Checklist (2026) for free.

How to Verify Whether Your Item Is EAR99

[EAR99 verification flow]

STEP 1  Is the item subject to the EAR? (15 CFR 734.3)
        - U.S.-origin item or export from the U.S. ............. subject
        - Controlled U.S. content above the de minimis level ... subject
        - Direct product of U.S.-origin technology ............. subject
        - Published information, ITAR articles, etc. ........... not subject (stop here)

STEP 2  Does it match an ECCN on the CCL?
        - Obtain the supplier's classification (fastest route)
        - Search the Interactive CCL by keyword
        - If still unclear, file a classification request with BIS (CCATS)

STEP 3  No ECCN applies
        Result: EAR99 (record the date, the basis, and who checked it)

The fastest reliable route is asking the U.S. manufacturer or supplier for the classification directly. Many major U.S. manufacturers publish ECCN and EAR99 designations; when they do not, route the request through procurement. Here is the request skeleton we give our customers:

Subject: Request for Export Classification Information (ECCN / EAR99)

We request the export classification of your product (Model: XXXX) under the U.S. Export Administration Regulations: (1) the ECCN or EAR99 designation, (2) the basis of classification (CCATS number if available), and (3) whether the item incorporates encryption functionality. This information will be used in our export and re-export compliance procedures.

If supplier confirmation does not settle it, search the BIS Interactive Commerce Control List by keyword. For how the code itself reads, see What an ECCN number is and how to look one up; for common numbers, the ECCN number list and quick-reference tables is faster. The formal fallback is a Classification Request to BIS through SNAP-R, which returns a CCATS determination⁴. BIS commits to answering classification requests within 14 calendar days of receipt⁵.

Whichever route you take, record the same things: the model and version, who answered and when, the exact wording of the answer (an ECCN, EAR99, or not subject to the EAR), the basis (a CCATS number or the manufacturer's published page), and who on your side reviewed it. The EAR requires export records to be kept for five years, counted from the latest of the export, any known reexport, or the end of the transaction⁶. If you capture the answer in that shape the day it arrives, it is ready for an audit or a customer question without rework.

EAR99 is not the same as Japan's "non-applicable"

If you buy from or sell into Japan, you will see a second determination next to the EAR one. Japanese suppliers issue classification certificates under the Foreign Exchange and Foreign Trade Act (FEFTA), and many publish their Japanese result and their EAR result (an ECCN or EAR99) side by side⁷. Customers often want both on one page.

The trap is treating "non-applicable" (hi-gaito) and "EAR99" as synonyms. Non-applicable means the item falls outside Japan's list controls (Items 1 to 15 of Appended Table 1 of the Export Trade Control Order). EAR99 means the item matches no ECCN on the U.S. CCL. Different criteria, so the answers can diverge. An item can be non-applicable in Japan and still fall under a U.S.-only entry, such as a 99-series ECCN like 3A991. A Japanese product with no U.S.-origin content may not be subject to the EAR at all.

If you issue these certificates, keep the FEFTA field and the EAR field separate, and put "EAR99," the applicable ECCN, or "not subject to the EAR" in the EAR field along with the determination date and basis. A certificate that says "non-applicable" with an empty EAR field leaves the recipient unable to tell whether anyone checked the U.S. side. Japanese document formats are covered in our guide to certificates of non-applicability, and templates are in the 2026 classification certificate pack.

Three Cases Where EAR99 Items Still Require a License

This is the operational core. EAR99 items carry no item-based license requirement, but the EAR's General Prohibitions that turn on destination, counterparty, and end use apply in full⁴. For destination-by-destination detail and the license exceptions available, see our companion piece on when EAR99 still requires a license. Here I will stick to the skeleton.

1. Destination

Cuba requires a license for all items subject to the EAR, EAR99 included, with only narrow license exceptions. North Korea is the same, except for EAR99 food and medicine⁸. Iran adds a second layer: on top of BIS licensing, the Treasury Department's Office of Foreign Assets Control (OFAC) runs a comprehensive embargo under the Iranian Transactions and Sanctions Regulations that reaches EAR99 goods. For Russia and Belarus, every item with an ECCN needs a license, and EAR99 items identified by HTS code, including listed industrial and luxury goods, need one too⁹. The occupied Crimea region of Ukraine and the other covered regions require a license for nearly everything outside EAR99 food and medicine.

Syria is the exception that moved. The regulation still states a license requirement for items including EAR99, but a September 2, 2025 rule created License Exception SPP (Syria Peace and Prosperity), which authorizes exports and reexports of EAR99 items to Syria unless a Part 744 end-use or end-user control applies¹⁰. Our February edition put Syria on the "EAR99 still needs a license" side. That was already out of date when we published it, and I have corrected it here.

2. End user

Exports to Entity List parties can require a license regardless of EAR99 designation, depending on the terms of each entry. Parties on the Denied Persons List are barred from transactions involving items subject to the EAR altogether. Then there is the Affiliates Rule. On September 30, 2025, BIS published it (90 FR 47201), automatically extending certain end-user restrictions to entities owned 50 percent or more, in aggregate, by listed parties¹¹. A November 12, 2025 Federal Register notice stayed the rule through November 9, 2026, with the provisions coming back the next day absent an extension². On September 28, 2026, China's Ministry of Commerce stated in an official explainer that the U.S.-China Kuala Lumpur joint arrangement, which includes the suspension of the 50% rule, is extended to January 10, 2027¹². The U.S. Treasury Secretary was reported to have said the same on September 23. As of October 4, BIS had not published an extension, so the stay date in the regulation is still November 9. Extended or not, you will need to know whether each counterparty is an affiliate of a listed party. The current status and the ownership math are in our BIS 50% rule guide, and the internal workflow is in the BIS 50% Rule compliance checklist (PDF).

3. End use

If there is reason to suspect use in connection with weapons of mass destruction (nuclear, chemical, biological, or missile programs) or certain military end uses, a license is required even for EAR99 items⁴. The military end-use rule covers only the items listed in its supplement for Burma, Cambodia, China, Nicaragua, and Venezuela, but for military end uses and military end users in Russia and Belarus it covers any item subject to the EAR, EAR99 included¹³. Red-flag management earns its keep here. A customer refuses to disclose end use. Product capability does not match the customer's line of business. An unusual shipping route or payment arrangement appears. BIS's position is that once you see a red flag, you do not proceed until the concern is resolved. Whether your organization can actually stop a deal under revenue pressure is, in my view, the real test of an export control program.

The stakes are worth stating plainly. Under the Export Control Reform Act, the inflation-adjusted civil penalty is up to $374,474 per violation or twice the value of the transaction, whichever is greater¹⁴. Criminal penalties reach $1 million in fines and up to 20 years in prison¹⁵. Nothing in the penalty provisions goes easier on EAR99.

Practical summary: with EAR99, the item review is light and the transaction review is heavy. Counterparty screening and ownership checks will be needed whichever way the Affiliates Rule deadline goes, so the real question is how to make that work sustainable. For multi-jurisdiction transaction screening support, TRAFEED is one option (more below).

EAR99 vs. ECCN, and the 99-Series Trap

To use EAR99 correctly, you still need ECCN structure. ECCNs are the full set of entries on the CCL (15 CFR Part 774), and they do not fit on one short page. Learn the 0 to 9 categories and A to E product groups first, then look up individual numbers on BIS's Interactive CCL or the eCFR.

An ECCN is a five-character alphanumeric code. Take 3A001: the leading 3 is the category (electronics), the A is the product group (equipment and components), and the three digits that follow show the type of control and the specific entry¹⁶.

Category	Scope
0	Nuclear materials, facilities, equipment, and miscellaneous
1	Materials, chemicals, microorganisms, and toxins
2	Materials processing
3	Electronics
4	Computers
5	Telecommunications and information security (including encryption)
6	Sensors and lasers
7	Navigation and avionics
8	Marine
9	Aerospace and propulsion

Group	Scope
A	Systems, equipment, and components
B	Test, inspection, and production equipment
C	Materials
D	Software
E	Technology

Reasons-for-control codes and common numbers are in the ECCN number list and quick-reference tables; a step-by-step explanation of what the code means and how to find yours is in What Is an ECCN?.

EAR99 is not 3A991 or 5A992.c

The mix-up I see most often is EAR99 versus ECCNs that end in a 99-series number. The digits in an ECCN show the reason for control, and the 990 to 999 range is used for anti-terrorism (AT), regional stability (RS), and similar controls¹⁶. Entries such as 3A991 (certain electronic devices and components), 4A994 (certain computers), and 5A992.c (mass-market encryption items) live here. Laptops, smartphones, and other consumer products with encryption are often classified by their manufacturers as 5A992.c rather than EAR99.

Items under these entries can ship to many destinations without a license, so they behave a lot like EAR99. But they are listed on the CCL, and that widens the set of destinations where a license is needed. Russia and Belarus make it obvious: every item with an ECCN requires a license there⁹. An EAR99 item, by contrast, needs one on item grounds only when it falls within the HTS-code lists (military end-user controls apply separately). If your team reads "3A991" on a supplier response as "basically EAR99," or records only "99" in the item master, that difference disappears. Keep the supplier's exact string.

EAR99 vs NLR: EAR99 is an item classification. NLR (No License Required) is a shipment determination for a specific transaction. An EAR99 item is not automatically NLR when destination, end user, or end use triggers a license. Mixing the two fields on the same form is a common audit weakness.

De Minimis: Do EAR99 Parts Count?

The de minimis rule can take a foreign-made product outside the EAR for reexport when its U.S.-origin content falls below a threshold: 10 percent for destinations in Country Groups E:1 and E:2 (Iran, North Korea, Syria, and Cuba) and 25 percent for everywhere else¹⁷.

This is where EAR99 matters. The numerator is not all U.S.-origin content, only controlled U.S.-origin content. BIS's guidelines tell you to ask, for each U.S.-origin item in the product, whether it would need a license if exported in the form you received it to the product's destination, using the Commerce Country Chart and the embargo and sanctions controls in Part 746, and not to count anything that could go NLR or under License Exception GBS¹⁸. Since EAR99 parts ship license-free to most destinations, they usually stay out of the numerator. For destinations where EAR99 itself needs a license, such as Cuba or North Korea, they count. Our February edition summed all U.S.-origin content in its example, which was not accurate.

A worked example. Your product sells for $10,000. It contains a U.S.-made electronic component classified 3A991 (cost $1,500) and U.S.-made EAR99 software bundled with it (license cost $500). Shipped to Thailand, the 3A991 part needs no license (its AT control does not reach Thailand), and neither does the EAR99 software, so controlled U.S. content is $0. Unless the Foreign Direct Product Rule applies, EAR reexport controls do not attach to that product. Shipped to North Korea, both items need a license, so controlled content is $2,000, or 20 percent, above the 10 percent threshold, and the product itself becomes subject to the EAR. Same product, opposite conclusions.

A few cautions. Software bundled with and configured for the product can be counted together with the hardware, but only if that software is EAR99 or controlled for AT reasons only; any other software needs its own assessment. If you commingle U.S.-origin technology with foreign technology, you must file a one-time report with BIS before relying on de minimis. Some items get no de minimis treatment at all, including foreign technology that incorporates U.S. encryption technology under 5E002 and certain advanced computers and semiconductor manufacturing equipment¹⁷. Products made from U.S.-origin technology may fall under the Foreign Direct Product Rule rather than de minimis, and you are expected to document your calculation method and the values you used. When the FDP boundary is unclear, ask specialist counsel or BIS rather than guessing. What the FDPR covers, the eleven FDP paragraphs in 734.9, and how the rule differs from de minimis are explained in the Foreign Direct Product Rule explained for Japanese companies.

What Changed Since the February 2026 Edition

This article first went up in February 2026. Here is what has moved since then, and where I corrected the original.

Topic	February 2026 edition	Now (as of October 4, 2026)
Affiliates Rule (50% rule)	Stayed through November 9, 2026; scheduled to return November 10	The stay in the Federal Register still ends November 9. The U.S. and China announced an extension to January 10, 2027 (stated officially by China's Ministry of Commerce on September 28; the U.S. Treasury Secretary's September 23 remarks are press reports). No BIS extension published yet
EAR99 to Syria	License generally required, as an embargoed destination	License Exception SPP since September 2, 2025: EAR99 items can go without a license application unless a Part 744 control applies (the February text was already out of date)
Entity List	Not covered	Of the 12 BIS rules published in the Federal Register in 2026, the only Entity List actions were one removal and one address revision. No additions
De minimis numerator	Example summed all U.S.-origin content	Only U.S.-origin content that needs a license to the destination counts. EAR99 parts usually do not count (corrected)
Penalties	Not covered	Civil penalties up to $374,474 per violation or twice the transaction value (inflation-adjusted); criminal penalties up to $1 million and 20 years

The first row is the one that matters most. Plenty of companies have been running November 10 internally as a fixed deadline, and the extension news has produced a "no need to hurry" mood. I see it a little differently. An extension has no legal effect until it appears in the Federal Register, it only adds two months, and the rule itself has not been withdrawn. My recommendation is a two-step approach: keep preparing for November 10 until an extension is published, then move your internal deadline the day it is. I will update this article when the Federal Register does.

On the third row, some context. The absence of new Entity List additions in 2026 coincides with the U.S.-China truce period. That does not mean listed parties have disappeared, and the Denied Persons List and OFAC's SDN List move on their own schedules. A listing is a regulatory designation, not a judgment about the company. Whether your own transaction is covered still has to be checked, and the quiet year is not a reason to stop screening.

The second and fourth rows are corrections to the original. Both bear directly on how freely EAR99 items can move. Syria opened up through a license exception, and EAR99 parts usually stay out of the de minimis numerator. Read correctly, both make the day-to-day work lighter, not heavier.

The 15-Item EAR Compliance Checklist

Even if you handle nothing but EAR99 items, every item in the transaction-review phase (6 to 10) and the recordkeeping phase (14 and 15) still applies.

Preliminary review

No.	Check item	What to verify
1	Does your product contain U.S.-origin items?	Components, software, and technology, all three
2	ECCN or EAR99 for each U.S.-origin item	Confirm with the supplier and record the date and basis. Do not confuse 99-series ECCNs with EAR99
3	What is the de minimis percentage?	Count only U.S.-origin content that needs a license to the destination
4	Does the Foreign Direct Product Rule apply?	Whether the item derives from controlled U.S.-origin technology
5	What is the destination?	Country Chart and embargoed-country lists

Transaction review

No.	Check item	What to verify
6	Who is the end user?	Screen against the Entity List and the Military End-User (MEU) List
7	Check the end user's affiliates	Include entities owned 50% or more (Affiliates Rule stayed as of October 2026; watch for the extension in the Federal Register)
8	What is the end use?	Military or WMD-related end uses
9	Screen against the DPL and the Unverified List (UVL)	Denied parties and parties whose bona fides BIS could not verify
10	Verify intermediaries	Shell-company and diversion risk

License determination

No.	Check item	What to verify
11	Do license exceptions apply?	Conditions for TMP, RPL, TSR, SPP, and others
12	Is a license application required?	Combined judgment of classification, destination, and end use
13	Deemed export exposure	Technology disclosure to foreign persons, including inside the U.S.

Recordkeeping

No.	Check item	What to verify
14	Retain transaction records	Five years, from the latest of export, known reexport, or end of the transaction
15	Record red flags	Concerns recognized during the transaction and how they were resolved

If I had to pick the two items most likely to slip, they would be 2 and 7. With item 2, teams get an answer once and keep using it for years with no date and no basis attached. Since ECCNs can change, an undated record cannot answer the obvious audit question: classified as of when? Item 7 keeps getting pushed back because the stay-and-extension story makes it feel distant. But checking shareholder structures one counterparty at a time is not something you can finish in the last few weeks. Start with your main counterparties and record ownership percentages along with the date you checked them.

How TRAFEED Supports EAR Compliance

For companies that also operate under non-U.S. regimes such as Japan's FEFTA, the hard part is running two systems at once: checking the ECCN or EAR99 a supplier gave you, screening counterparties and their affiliates, and doing the home-country classification. Each step is simple alone. Running all of them on every transaction adds up.

TRAFEED, TIMEWELL's AI agent for export-control teams, is built to take some of that load. To be clear up front: it does not determine ECCNs or EAR99. For the U.S. EAR, it reads the ECCN or EAR99 stated in suppliers' classification documents and flags inconsistencies with the item data or entries that look out of date. It runs restricted party screening against the U.S. Consolidated Screening List, including the Entity List and SDN List, and other countries' sanctions lists, and it traces ownership to surface counterparties that could fall under the 50% rule. When ownership percentages are unknown, it routes the case to a person for review. For Japan's export classification under FEFTA, it maps items against Appended Table 1 from specs and part numbers and shows the clauses relied on. Product-side support for the 50% rule is described on our BIS 50% Rule page.

TRAFEED is a decision-support tool. Your export control officer makes the final call. Every result shows the clause or list entry it relied on, and the evidence and approvals stay in one place, so the trail survives staff turnover. Keeping that line intact is what a healthy export control program looks like.

Closing

If EAR99 needs a one-line summary: a classification inside the EAR that carries no item-based controls. The points worth carrying into your next review:

• The EAR is the framework, an ECCN is a CCL list number, and EAR99 is the catch-all inside the EAR when no ECCN applies
• EAR99 is a conclusion after reviewing the CCL, not "unregulated." There is no EAR99 inventory, and classifications can change over time
• "Not subject to the EAR" is a different concept (published information, ITAR articles), and Japan's "non-applicable" is a separate Japanese determination
• 99-series ECCNs such as 3A991 and 5A992.c are not EAR99, and the difference shows up for destinations like Russia and Belarus
• EAR99 items still need a license for embargoed destinations, restricted end users, and end-use concerns. Syria has had License Exception SPP for EAR99 items since September 2025
• Only U.S.-origin content that needs a license to the destination counts toward de minimis, so EAR99 parts usually do not
• The Affiliates Rule is stayed through November 9 in the Federal Register. An extension to January 10, 2027 has been announced but not published. Ownership screening is worth doing regardless of the date

Export control in practice depends less on memorizing the regulations than on building verification habits into daily work. With the dates still moving this year, the most useful thing you can do on Monday is make sure every supplier classification and every ownership check carries an "as of" date. Take this article and the checklist into your next compliance meeting as they are.

To streamline EAR-related screening and multi-jurisdiction workflows, see TRAFEED. For a discussion of your own situation, book a consultation. Product overview: TRAFEED service catalog (PDF).

---

References

Additional references: The White House, "Fact Sheet: President Donald J. Trump Strikes Deal on Economic and Trade Relations with China" (November 1, 2025; states the one-year suspension of the Affiliates Rule); JETRO business brief on the third U.S.-China summit fact sheet, referencing the Treasury Secretary's September 23 remarks (September 28, 2026, Japanese); CISTEC, "Q&A on EAR Re-export Controls, Rev. 8" (February 19, 2026, Japanese); BIS, "Interactive Commerce Control List".

Related Articles

• What Is an ECCN? How to Read the Code and Look Up Your Product's ECCN
• ECCN Number List and Quick-Reference Tables (2026 Edition)
• When EAR99 Still Requires an Export License
• What Is the BIS 50% Rule? Stay Deadline, Extension Deal, and Ownership Math
• Guide to Non-Applicability Certificates (Japan FEFTA)
• Five Steps to Streamline Export Classification
• Building an Export Control Program from Zero in 10 Steps

Footnotes

1. BIS, "Classify your item" (includes the EAR99 definition and the caution that ECCNs may change over time) — U.S. Department of Commerce, Bureau of Industry and Security ↩ ↩² ↩³

2. "One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities," 90 FR 50857 — Federal Register (published November 12, 2025; stayed through November 9, 2026) ↩ ↩²

3. 15 CFR Part 734, "Scope of the Export Administration Regulations" — BIS ↩ ↩²

4. 15 CFR Part 732, "Steps for Using the EAR" — BIS ↩ ↩² ↩³

5. 15 CFR 750.2, "Processing of Classification Requests and Advisory Opinions" — eCFR ↩

6. 15 CFR 762.6, "Period of retention" — eCFR ↩

7. Hirose Electric, "Notice on Export Control Classification and EAR Determination Results" (Japanese; example of publishing Japanese classification and EAR results together) ↩

8. 15 CFR Part 746, "Embargoes and Other Special Controls" — BIS ↩

9. 15 CFR 746.8, "Sanctions against Russia and Belarus" — eCFR ↩ ↩²

10. "Relaxing Export Controls for Syria," 90 FR 42315 — Federal Register (published September 2, 2025; License Exception SPP is at 15 CFR 740.5) ↩

11. "Expansion of End-User Controls To Cover Affiliates of Certain Listed Entities," 90 FR 47201 — Federal Register (published September 30, 2025) ↩

12. Ministry of Commerce of the People's Republic of China, explainer on the outcomes of the eighth round of China-U.S. economic and trade consultations (September 28, 2026; item 8 states the extension of the Kuala Lumpur joint arrangement to January 10, 2027) (Chinese) ↩

13. 15 CFR 744.21, "Restrictions on certain military end uses or military end users" — eCFR ↩

14. 15 CFR 6.3, "Adjustments for inflation to civil monetary penalties," paragraph (c)(6) — eCFR ↩

15. 50 U.S.C. 4819, "Penalties" — U.S. Code ↩

16. 15 CFR 738.2, "Commerce Control List (CCL) structure" — eCFR ↩ ↩²

17. 15 CFR 734.4, "De minimis U.S. content" — eCFR ↩ ↩²

18. 15 CFR Part 734, Supplement No. 2, "Guidelines for De Minimis Rules" — eCFR ↩