Controlled / Dual Use IT Goods Classification Guide

International trade and customs regulations dictate that much of the IT technology portfolio is banded under a “Restricted Dual Use” and classified as Controlled Goods – this criteria stipulates that the movement of these goods must be tracked from source to final destination.
In order to identify what goods are, whether or not they are controlled, and how they are classified, several lists have been created. These are as follows:

ECCN Number 

ECCN stands for ‘Export Control Classification Number’. The ECCN is an alpha-numeric designation (i.e., 1A984 or 4A001) used in the Commerce Control List to identify items for export control purposes. 

An ECCN categorises items based on the nature of the product, i.e. type of commodity, technology or software and its respective technical parameters.

The first number identifies the primary category

EU Dual-Use List Categories

  • Category 0 - Nuclear materials, facilities and equipment
  • Category 1 - Special materials and related equipment
  • Category 2 - Materials processing
  • Category 3 - Electronics
  • Category 4 - Computers
  • Category 5 - Telecommunications and “information security”
  • Category 6 - Sensors and lasers
  • Category 7 - Navigation and avionics
  • Category 8 - Marine
  • Category 9 - Aerospace and Propulsion

The second number is for the sub-category

  • A - Systems, equipment and components
  • B - Test, inspection, production equipment
  • C - Materials
  • D - Software
  • E - Technology

The third number reflects the Originating Regime or Arrangement the goods fall under

  • 0 - Wassenaar Arrangement
  • 1 - Missile Technology Control Regime
  • 2 - Nuclear Suppliers Group
  • 3 - Australia Group
  • 4 - Chemical Weapons Convention

The are two more digits, and they are for there for a detailed goods description and may be followed by further sub categories.

Originating Regimes or Arrangements

  • A - Australia Group
  • C - Chemical Weapons Convention (CWC)
  • M - Missile Technology Control Regime (MTCR)
  • N - Nuclear Suppliers Group (NSG) Dual-Use List
  • T - Nuclear Suppliers Group (NSG) Trigger List
  • W - Wassenaar Agreement
  • WS - Wassenaar Agreement Sensitive List
  • WVS - Wassenaar Agreement Very Sensitive List

Most IT goods will fall under “5A002a” or “4A002a” – but this is not exclusive. 

EAR99

EAR99 is a classification for an item. It indicates that an item is subject to the Export Administration Regulations (EAR), but is not specifically described by an Export Control Classification Number (ECCN) on the Commerce Control List (CCL). Items that fall under the jurisdiction of the EAR are not found on the Commerce Control List (CCL).

HS Codes

In addition to an ECCN number, goods also have a HS Code. The Harmonized Commodity Description and Coding System, also known as the Harmonized System (HS Code) of tariff nomenclature, is an internationally standardised system of names and numbers to classify traded products. 

Developed by the World Customs Organization (WCO), HS codes are used to classify and define internationally traded goods. The list of HS codes is long and extensive, but can be easily located online from many tariff websites.

Mouse and Bear has many years' experience helping companies understand ECCN and Dual Use classifications, and guiding them through this complex area of importing. Our expert services will ensure smooth movement of your goods from source to end destination.

Please get in touch with Mouse & Bear if you need advice on this. Note that vendors will have already classified their goods so they will also be able to assist.


 

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