Calder & Vance International Sanctions & Compliance Counsel

Glossary

EAR99 and ECCN

An ECCN (Export Control Classification Number) identifies a controlled item on the Commerce Control List; EAR99 is the residual category for items subject to the regulations but not specifically listed. Classification determines whether a licence is required.

A worked example and links to the primary regulators are added in Phase 2. For how this applies to a specific matter, a fixed-fee written position is the proportionate step.

Related terms

SDN vs sectoral sanctions The OFAC 50% Rule Ownership vs control (EU) General vs specific licence

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