Export Control Studio
PlansAccount

New to export control? Start here.

Learn the six steps of every export check, then the words you'll see along the way.

About 5 minutes · general information, not legal advice

How every export check works

Six steps, always in this order. Tap a step to learn what it means, or follow an example shipment.

Follow an example

The six steps

  1. 1 · What is it?
  2. 2 · Where is it going?
  3. 3 · Who gets it?

Where you end up

  • No license needed
  • License or License Exception
  • ITAR license or exemption
  • Stop and get help

1 · What is it?Step 1 of 6

Which rulebook covers it: EAR or ITAR?

What it asks
Whether the item is a defense item on the U.S. Munitions List (ITAR, State Department) or anything else (EAR, Commerce Department).
Why it matters
The two rulebooks work differently. Under the ITAR almost every export needs a license or an exemption. Under the EAR, many items need no license at all. Most products are EAR.

Learn more:EAR →ITAR →USML →EAR or ITAR? →

Compare EAR and ITAR

How an ECCN and a country fit together

Each ECCN lists its reasons for control. The Country Chart marks which countries need a license for each reason. Pick a country to see the check.

The item

2B001

Machine tools for cutting metal

Its reasons for control
NS2
National security, column 2
NP1
Nuclear nonproliferation, column 1
AT1
Anti-terrorism, column 1
Where is it going?
Commerce Country Chart (three of its columns)
CountryNS2NP1AT1
Germany···
India·X·
ChinaXX·
IranSee EAR Part 746 (embargo)
No X in this item's columns

No license is needed for these reasons (NLR). You still check the parties and the end use before you ship.

Simplified from the Commerce Country Chart. Some 2B001 paragraphs carry fewer reasons, and other EAR rules can still apply. Run the real check on the License check page.

The words you'll see

Grouped by the three questions. The tag shows which rulebook uses the word.

The basics The two rulebooks, and what counts as an export

ExportWhat counts

Both

Sending an item, software or technical information out of the United States. Showing or giving controlled technical information to a foreign person inside the U.S. can count too.

Emailing design drawings to a supplier in Mexico is an export, even though nothing ships.

EAR 15 CFR 734.13 · ITAR 22 CFR 120.50

EARExport Administration Regulations

EAR

The Commerce Department's export rules. They cover most commercial products, software and technology, including items with both civilian and military uses.

Laptops, sensors, machine tools, chemicals, encryption software.

15 CFR Parts 730–774 · run by BIS

ITARInternational Traffic in Arms Regulations

ITAR

The State Department's rules for defense items: things on the U.S. Munitions List, their technical data, and defense services.

Missile parts, parts made for military aircraft, training a foreign military to maintain a weapon.

22 CFR Parts 120–130 · run by DDTC

EAR or ITAR?Jurisdiction

Both

Before anything else, work out which rulebook applies. Check the U.S. Munitions List first. If the item isn't described there, it is usually under the EAR.

Not sure? The State Department can decide through a commodity jurisdiction (CJ) request.

ITAR 22 CFR 120.11 (order of review), 120.4 (CJ)

1 · What is it? Finding the item on a control list

CCLCommerce Control List

EAR

The EAR's list of controlled items. It has 10 categories (0 to 9), each split into 5 product groups (A to E).

Groups: A equipment, B test and production equipment, C materials, D software, E technology.

Supplement No. 1 to 15 CFR Part 774

ECCNExport Control Classification Number

EAR

The five-character code for an item on the CCL. It tells you why the item is controlled.

2B001: category 2 (materials processing), group B (production equipment), entry 001 (machine tools).

15 CFR 738.2

EAR99Not on the list

EAR

The label for items that are subject to the EAR but not on the CCL. Most everyday products are EAR99.

Usually no license is needed, except for embargoed countries, restricted parties or prohibited end uses.

15 CFR 734.3(c)

USMLU.S. Munitions List

ITAR

The ITAR's list of defense items, in 21 categories (I to XXI). An item is named by its category and paragraph.

Category VIII is aircraft. VIII(h)(1) covers parts made for certain military aircraft.

22 CFR 121.1

2 · Where is it going? How the destination changes the answer

Reason for controlNS, NP, AT and others

EAR

Why an item is controlled, written as a short code. Each ECCN lists one or more.

NS national security, NP nuclear, MT missiles, CB chemical and biological, RS regional stability, AT anti-terrorism.

15 CFR Part 742

Country ChartCommerce Country Chart

EAR

A grid of countries against reasons for control. An X means a license is needed for that reason, unless an exception applies.

Find the country's row, then look only at the columns your ECCN lists.

Supplement No. 1 to 15 CFR Part 738

License checkECCN × country

EAR

Match the item's reasons for control against the destination's row on the Country Chart. No X means no license for those reasons. An X means you need a license or a license exception.

It's a first step: embargoes, end use and the parties can still require a license.

15 CFR 738.4

Embargoed countrySpecial destination rules

Both

A few destinations have much stricter rules, and most exports to them need a license.

Cuba, Iran, North Korea, Syria, Russia and Belarus under the EAR. The ITAR keeps its own list of restricted countries.

EAR 15 CFR Part 746 · ITAR 22 CFR 126.1

3 · Who gets it, and for what? The people and the purpose

Restricted partyDenied or listed party

Both

A person or company the U.S. government has put on a list. Dealing with them may need a license, or be banned outright.

Entity List, Denied Persons List, Unverified List (Commerce); debarred parties (State); SDN List (Treasury). The Consolidated Screening List searches them together.

15 CFR Part 744 · 22 CFR 127.7 · 31 CFR Ch. V

OFACOffice of Foreign Assets Control

Both

The Treasury office that runs U.S. sanctions. Some cover whole countries, like Iran or Cuba. Others target listed people and companies, like the SDN List.

Sanctions can block payments and services, not just shipments, and U.S. persons follow them wherever they are.

31 CFR Chapter V

End use and end userWhat it's for, and who uses it

EAR

What the item will finally be used for, and by whom. Some end uses need a license even for EAR99 items.

Nuclear, missile, or chemical and biological weapons work. Other rules cover military end uses in certain countries.

15 CFR Part 744

Then: the kind of OK you need Licenses, exceptions and exemptions

NLRNo License Required

EAR

The answer when the EAR needs no license for this export. It is not permission to ship: you still check the parties and the end use.

You'll see it on export filings, and as a result on the License check page.

15 CFR 758.1

LicenseGovernment permission

Both

Written permission from the government for a specific export. You apply to BIS under the EAR, or to DDTC under the ITAR.

A DSP-5 is the ITAR license for a permanent export of unclassified defense articles.

15 CFR Part 748 · 22 CFR Part 123

License ExceptionShip without a license, if every condition fits

EAR

A rule that lets some EAR exports go without a license. Each has a three-letter code and its own conditions.

LVS (limited value), TMP (temporary exports), ENC (encryption). General limits in § 740.2 can rule one out.

15 CFR Part 740

License ExemptionThe ITAR's version

ITAR

A specific situation where the ITAR needs no license. Exemptions are narrow, and you must keep records when you use one.

Some exports to Canada (§ 126.5), some technical data (§ 125.4).

22 CFR 123.16, 125.4, 126.5

EAR and ITAR compared

Many ideas have a twin in the other rulebook. A few work very differently.

EAR and ITAR compared
EARITAR
Parallels
Who runs itCommerce Department, through BISState Department, through DDTC
The rules15 CFR 730–77422 CFR 120–130
The control listCommerce Control List (CCL)U.S. Munitions List (USML)
The item's codeECCN, like 2B001Category and paragraph, like VIII(h)(1). There's no table that turns one into the other
Ship without a licenseLicense Exception (Part 740)License Exemption (for example § 126.5, § 125.4)
Get a licenseApply to BISApply to DDTC (for example a DSP-5), or an agreement for defense services
Restricted partiesEntity List, Denied Persons List, Unverified List, Military End-User ListDebarred parties (§ 127.7). OFAC's SDN List applies under both
Sharing know-how in the U.S.A "deemed export" to the foreign personAn export to the foreign person
Differences
What it coversCommercial products and items with both civilian and military uses, plus some less sensitive military items (the "600 series")Defense articles, their technical data, and defense services
Not on the listEAR99: still under the EAR, usually no licenseNot an ITAR item. Check whether the EAR applies
Does the country matter?Yes. The Country Chart decides for most listed itemsLess so. Almost every export needs a license or exemption; § 126.1 lists countries with stricter rules
No license neededNLR, for many item and country pairsNo general equivalent
Register firstNo registration to exportManufacturers and exporters must register and pay a yearly fee (Part 122)
Foreign-made productsDe minimis and foreign direct product rules decideNo de minimis: the U.S. part stays under the ITAR

General information to help you get started, not legal advice. The regulations control: EAR at 15 CFR Parts 730–774, ITAR at 22 CFR Parts 120–130, OFAC sanctions at 31 CFR Chapter V. Export Control Studio gives preliminary screening only, never a government determination or permission to ship.