My recent post “Got Alphabet Soup?” covered ECCNs (Export Control Classification Numbers) and EAR99 which is used for items subject to Export Administration Regulations without having a specific ECCN. License determination is the next step in export compliance and I remind shippers that automatically using EAR99 and NLR (No License Required) is risky.

§ 738.4 DETERMINING WHETHER A
LICENSE IS REQUIRED
(a) Using the CCL and the Country Chart
(1) Overview. Once you have determined that
your item is classified under a specific ECCN,
you must use information contained in the
“License Requirements” section of that ECCN in
combination with the Country Chart to decide
whether a license is required. Note that not all
license requirements set forth under the “License
Requirements” section of an ECCN refer you to
the Commerce Country Chart, but in some cases
this section will contain references to a specific
section in the EAR for license requirements. In
such cases, this section would not apply.

Contact mitch@52.91.45.227 for help with export regulations.