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Order of Review

Following Export Control Reform, many classifications for items determined prior to 2013 were no longer valid. To determine the current classification of an item, exporters should follow DDTC’s Order of Review. Exporters should first consider if the item is listed on the USML and if it falls within the definition of specially designed. If the item is not on the USML or is not considered “specially designed” for a defense article on the USML, exporters should review if the item falls within the enumerated 600 series ECCNs. If no 600 series ECCNs are applicable, other enumerated ECCNs should be considered. If the items falls outside the scope of all entries of the CCL, the classification of the item is EAR99.

 To affirm self-classifications and especially in instances where there is a question as to the classification, it is recommended that a State Department Commodity Jurisdiction (CJ) and/or a Commerce Department Classification Request (CCATS) be obtained for items.  Both classification submissions will allow for the confirmation of classification/jurisdiction, and thus allow for the proper licensing authority to be obtained prior to export.


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