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Classification procedures

For items or technology subject to export control regulations

 

Any item or technology that is subject to export control regulations can be found on either the United States Munitions List (USML) or the Commerce Control List (CCL). Items on the CCL are identified with a 5-character alpha-numeric designation known as the Export Control Classification Number (ECCN).

Before you can determine what authorization is required to export a listed item or technology, it must be “classified.” That is, you must determine which ECCN applies.

Classifying an item or technology is a key component of export control compliance. If an item or technology has not been classified or has been improperly classified, there is no way to determine if export control regulations apply to your situation.

Ways to determine classification

Self-classification

During the course of research, WSU research staff will often produce, develop, or manufacture new items or technologies. In these cases, the Bureau of Industry and Security (BIS) and Directorate of Defense Trade Controls (DDTC—an arm of the U.S. Department of State) encourage self-classification, because there is no one who will know the characteristics of the item or technology better than the inventor/creator.

Classification by the manufacturer

For purchased items, the best way to obtain export classification is to request it from the manufacturer or developer.

The University recommends that you request the commodity classification via e-mail so that a record exists that can be saved for future inquiries. Many companies also have export information available on their websites.

Request a commodity jurisdiction determination or commodity classification

In the event that the manufacturer cannot provide an export classification or you are unable to perform a self-classification, you have the option to request guidance from either the DDTC or the BIS.

Upon request the DDTC will determine commodity jurisdiction: whether an item or service falls within the scope of the U.S. Munitions List (USML) and is therefore subject to export controls administered by the Department of State.

If it has been determined that your scope of work does not fall within the DDTC regulations and you still need further clarification, you can request a commodity classification from BIS to see if your item or technology is subject to the Commerce Control List (CCL).