出口管制分类号

确定是否需要从商务部获得出口许可证的关键是确定您打算出口的物品是否具有特定的出口控制分类编号(ECCN)。 出口管制编号是在《商业管制清单》(CCL)上使用的五个字符字母数字编号,用以识别军民两用物品,以作出口管制用途。  An ECCN categorizes items based on the nature of the product, i.e., type of commodity, software, or technology and its respective technical parameter.

To determine if your item or technology has an ECCN number, the Bureau of Industry and Security (BIS) provides information on the CCL for your convenience.

Need to get an Item or Technology Classified?

Drexel University’s Export Team can assist you in obtaining the correct classification of your item. Please submit an ECCN Classification Request.

Key Terms for ECCN Classification

Accessories and Attachments

These are associated items for any “component,” “end item,” or “system,” and which are not necessary for their operation, but which enhance their usefulness or effectiveness. For example, for a riding lawnmower, “accessories” and “attachments” will include the bag to capture the cut grass, and a canopy to protect the operator from the sun and rain. For purposes of this definition, “accessories” and “attachments” are the same.

Component

This is an item that is useful only when used in conjunction with an “end item.” “Components” are also commonly referred to as assemblies. For purposes of this definition an assembly and a “component” are the same. There are two types of “components”: “major components” and “minor components.” A “major component” includes any assembled element which forms a portion of an “end item” without which the “end item” is inoperable. For example, for an automobile, “components” will include the engine, transmission, and battery. If you do not have all those items, the automobile will not function, or function as effectively. A “minor component” includes any assembled element of a “major component.” “Components” consist of “parts.” References in the CCL to “components” include both “major components” and “minor components.”

End Item

This is an assembled commodity ready for its intended use. Only ammunition, fuel or other energy source is required to place it in an operating state. Examples of end items include ships, aircraft, computers, firearms, and milling machines.

Equipment

This is a combination of parts, components, accessories, attachments, firmware, or software that operate together to perform a function of, as, or for an end item or system. Equipment may be a subset of “end items” based on the characteristics of the equipment. Equipment that meets the definition of an end-item is an end-item. Equipment that does not meet the definition of an end-item is a part, component, accessory, attachment, firmware, or software.

Material

This is any list-specified crude or processed matter that is not clearly identifiable as any of the types of items defined in § 772.1 under the defined terms, “end item,” “component,” “accessories,” “attachments,” “part,” “software,” “system, “equipment,” or “facilities.” The exclusion from the definition of material for clearly identifiable items defined in § 772.1, such as for “parts” and “components,” does not apply to the following ECCNs: 1C233, 1C234, 1C235, 1C236, 1C237, 1C239, 1C350, 1C395, 1C991, 1C992, and 1C995.

Part

This is any single unassembled element of a “component,” “accessory,” or “attachment” which is not normally subject to disassembly without the destruction or the impairment of design use. Examples include threaded fasteners (e.g., screws, bolts, nuts, nut plates, studs, inserts), other fasteners (e.g., clips, rivets, pins), common hardware (e.g., washers, spacers, insulators, grommets, bushings), springs and wire.

Production Equipment

(Missile Technology Control Regime (MTCR) context) — Tooling, templates, dies, fixtures, alignment mechanisms, test equipment, other machinery and components therefor, limited to those specially designed or modified for “development” or for one or more phases of “production”.

Software

A collection of one or more “programs” or “microprograms” fixed in any tangible medium of expression.

Technology

(General Technology Note) Specific information necessary for the “development”, “production”, or “use” of a product. The information takes the form of “technical data” or “technical assistance”. Controlled “technology” is defined in the General Technology Note and in the Commerce Control List (Supplement No. 1 to part 774 of the EAR). “Technology” also is specific information necessary for any of the following: operation, installation (including on-site installation), maintenance (checking), repair, overhaul, refurbishing, or other terms specified in ECCNs on the CCL that control “technology.”

N.B.: Technical assistance - May take forms such as instruction, skills training, working knowledge, consulting services.

Note 1:"Technical assistance" may involve transfer of "technical data".

Note 2:“Technology” not elsewhere specified on the CCL is designated as EAR99, unless the “technology” is subject to the exclusive jurisdiction of another U.S. Government agency (see § 734.3(b)(1)) or is otherwise not subject to the EAR (see § 734.4(b)(2) and (b)(3) and §§ 734.7 through 734.11 of the EAR).

600 Series

ECCNs in the “xY6zz” format on the Commerce Control List (CCL) that control items on the CCL that were previously controlled on the U.S. Munitions List or that are covered by the Wassenaar Arrangement Munitions List (WAML). The “6” indicates the entry is a munitions entry on the CCL. The “x” represents the CCL category and “Y” the CCL product group. The “600 series” constitutes the munitions ECCNs within the larger CCL.

9x515

9x515 ECCNs describe "spacecraft," related items, and some radiation-hardened microelectronic circuits that were once subject to the ITAR and USML Category XV. Just as the ITAR effectively trumps the EAR, items described in a 9x515 ECCN or "600 series" ECCN trump other ECCNs on the CCL.

EAR99

Items subject to the EAR that are not elsewhere specified in this CCL Category or in any other category in the CCL are designated by the number EAR99.

Specially Designed

When applying this definition, follow this sequential analysis set forth below. (For additional guidance on the order of review of "specially designed," including how the review of the term relates to the larger CCL, see Supplement No. 4 to Part 774 of the EAR - Commerce Control List Order of Review.)

  1. Except for items described in (b), an "item" is "specially designed" if it:
    1. As a result of "development" has properties peculiarly responsible for achieving or exceeding the performance levels, characteristics, or functions in the relevant ECCN or U.S. Munitions List (USML) paragraph; or
    2. Is a "part," "component," "accessory," "attachment," or "software" for use in or with a commodity or defense article 'enumerated' or otherwise described on the CCL or the USML.
  2. A "part," "component," "accessory," "attachment," or "software" that would be controlled by paragraph (a) is not "specially designed" if it:
    1. Has been identified to be in an ECCN paragraph that does not contain "specially designed" as a control parameter or as an EAR99 item in a commodity jurisdiction (CJ) determination or interagency-cleared commodity classification (CCATS) pursuant to § 748.3(e);
    2. Is, regardless of 'form' or 'fit,' a fastener (e.g., screw, bolt, nut, nut plate, stud, insert, clip, rivet, pin), washer, spacer, insulator, grommet, bushing, spring, wire, solder,;
    3. Has the same function, performance capabilities, and the same or 'equivalent' form and fit, as a commodity or software used in or with an item that:
      1. Is or was in "production" (i.e., not in "development"); and
      2. Is either not 'enumerated' on the CCL or USML, or is described in an ECCN controlled only for Anti-Terrorism (AT) reasons;
    4. Was or is being developed with "knowledge" that it would be for use in or with commodities or software (i) described in an ECCN and (ii) also commodities or software either not 'enumerated' on the CCL or the USML (e.g., EAR99 commodities or software) or commodities or software described in an ECCN controlled only for Anti-Terrorism (AT) reasons;
    5. Was or is being developed as a general purpose commodity or software, i.e., with no "knowledge" for use in or with a particular commodity (e.g., an F/A-18 or HMMWV) or type of commodity (e.g., an aircraft or machine tool); or
    6. Was or is being developed with "knowledge" that it would be for use in or with commodities or software described (i) in an ECCN controlled for AT-only reasons and also EAR99 commodities or software; or (ii) exclusively for use in or with EAR99 commodities or software.

Note 1:

Note 2:

A 'catch-all' paragraph is one that does not refer to specific types of "parts," "components," "accessories," or "attachments" but rather controls non-specific "parts," "components," "accessories," or "attachments" because they were "specially designed" for an enumerated item. For example, ECCN paragraph 9A610.x is a catch-all, because it controls "parts," "components," "accessories," and "attachments" "specially designed" for military aircraft, but does not identify specific types of "parts," "components," "accessories," or "attachments" within its control. Another example of a 'catch-all' is the heading of 7A102, which controls "specially designed" components for the gyros enumerated in 7A102, but does not identify the specific types of "components" within its control.

Note to paragraph (a)(1):

Note 1 to paragraph (b)(3):

Commodities in "production" that are subsequently subject to "development" activities, such as those that would result in enhancements or improvements only in the reliability or maintainability of the commodity (e.g., an increased mean time between failure (MTBF)), including those pertaining to quality improvements, cost reductions, or feature enhancements, remain in "production." However, any new models or versions of such commodities developed from such efforts that change the basic performance or capability of the commodity are in "development" until and unless they enter into "production.

Note 2 to paragraph (b)(3):

With respect to a commodity, 'equivalent' means that its form has been modified solely for 'fit' purposes.

Note 3 to paragraph (b)(3):

Note to paragraphs (b)(3) and (b)(4):

E

Note to paragraphs (b)(4), (b)(5) and (b)(6):

For a commodity or software to be not "specially designed" on the basis of paragraphs (b)(4), (b)(5) or (b)(6), documents contemporaneous with its "development," in their totality, must establish the elements of paragraphs (b)(4), (b)(5) or (b)(6). Such documents may include concept design information, marketing plans, declarations in patent applications, or contracts. Absent such documents, the "commodity" may not be excluded from being "specially designed" by paragraphs (b)(4), (b)(5) or (b)(6).