Understanding ITAR, CCL and EAR99 Classifications?

Under the export control regulations, every item can classified as being subject to ITAR, the CCL, another agency’s regulations, or else is designated as EAR99.  

What is ITAR?

ITAR stands for the International Traffic in Arms Regulations (22 CFR §§ 120-130), established by the Directorate of Defense Trade Controls within the U.S. Department of State. These regulations cover:

  • defense articles;
  • significant military equipment;
  • major defense equipment; 
  • defense services; and
  • technical data and software. 

The major items regulated under ITAR are identified in the United States Munitions List (USML).

What is CCL?

The Commerce Control List (CCL) identifies those items regulated by the commerce department's Bureau of Industry and Security (BIS). This includes export control, export and re-export of commercial and dual use items not subject to ITAR or other federal regulations. Dual use items are those with both commercial and military/security applications.

What items are controlled by other agencies?

The Department of Energy and the Nuclear Regulatory Commission also have specific export classifications for certain nuclear materials including:

  • plutonium;
  • uranium-233;
  • or uranium enriched above 0.711 percent by weight in the isotope uranium-235; and
  • reactor equipment 

What is EAR99?

Items not designated under the control of another federal agency or listed on the Commodity Control List (CCL) are classified as EAR99 (Export Administration Regulations). EAR99 items generally are low-technology consumer goods not requiring a license, however there are some exceptions. You might have to get a license if you are sending an item:

  • to an embargoed county; 
  • to an end-user of concern; or
  • in support of a prohibited end-use.
How do I classify my exports?

Answer the following questions in order. A yes answer determines your classification.

  1. Is the item subject to ITAR?
  2. Is the item subject to another federal agency’s export control regulations?
  3. Is the item on the CCL?
  4. If “No” to all of the above, the item is classified as EAR99.