The Commerce Control List (CCL) regulates and limits the export and re-export of specific U.S. goods, technology, and software using Export Control Classification Numbers (ECCNs). The ten categories under the CCL oversee a wide range of products, including electronics, computers, propulsion systems, and nuclear materials. It's important to note that numerous controlled products may appear harmless at first glance.

Why are some products and technology called out in the CCL while others aren't?

The CCL is based on the "reasons for control." These are various rationales for restricting the export of products, each with different perspectives and end goals in mind. A two-letter code can identify these reasons in the heading section of an ECCN.

The CCL's "Reasons for Control":

• A.T. Anti-Terrorism
• C.B. Chemical & Biological Weapons
• C.C. Crime Control
• C.W. Chemical Weapons Convention
• E.I. Encryption Items
• F.C. Firearms Convention
• M.T. Missile Technology
• N.S. National Security
• N.P. Nuclear Nonproliferation
• R.S. Regional Stability
• S.S. Short Supply
• U.N. United Nations Embargo
• S.I. Significant Items
• S.L. Surreptitious Listening

An export license may be required before you export, depending on the reason for control, the destination, or the end user.

The CCL controls exports for various reasons, and because of this, you see some peculiar ECCN call-outs such as:

• 0A980 - Horses on boats
• 1C988 - Western red cedar logs and timber
• 1C351 - African horse sickness virus

Why does the CCL control things that are seemingly simple and harmless?

Some items can be valuable and harmless in the hands of everyday people, but they can also be harmful if they fall into the wrong hands. This concept is known as "dual-use". The CCL regulates many items that could be misused by malicious individuals, leading to numerous ECCN (Export Control Classification Number) designations for everyday items. Many assume that export controls only apply to advanced or cutting-edge technology, but this is not true. It's often surprising for new exporters to learn these simple product-type controls exist.

Examples of items controlled by the CCL:

• 2A101 - Radial ball bearings
• 8A992 – Life jackets, compasses, and boat motors
• 7A994 – GPS products
• 2B999 - Valves and piping
• 9A991 – Civil aircraft parts
• 5A992 – Laptops and computers (mass market encryption commodities)

If you need professional help with export controls, Tradewin is here to assist you. Our team of experts can provide accurate commodity classifications and guidance to help your business export confidently.

Contact Tradewin today to ensure your exports comply with the correct export control classification number.