TRAFEED
When EAR99 Still Requires an Export Licence: Embargoed Destinations, End-Use and End-User Controls, and de minimis (2026 Edition)
What EAR99 is, explained from the ground up: it means "subject to the EAR but not listed on the CCL" (15 CFR 734.3(c)); the three-step classification flow; and the most misunderstood part — when an EAR99 item still needs a license (embargoes, end-use, end-user), plus de minimis, FDP, and how it relates to Japan's own classification. Based on primary sources, for export-control staff.
2026-07-29Ryuta Hamamoto
