Memo about the Commerce Control List & the ECCN codes
The Bureau of Industry and Security (BIS) is an agency of the United States Department of Commerce, which goal is to maintain the national security by regulating the export of sensitive goods, such as high technology products. To reexport or transfer any US-origin product, every company has to refer to the Export Administration Regulation (EAR) and even more on the Commerce Control List (CCL) that have been created by the BIS. The CCL contains all the ‘dual-use’ items, which means all the items that have both commercial and military or proliferation applications.
An ECCN code is needed to determine if a company is authorized to export a US-origin product or if a specific export license is needed. This code is five character alphanumeric.
The first number refers to the category of the group:
0 = Nuclear Materials, Facilities & Equipment (Miscellaneous Items)
1 = Materials, Chemicals, Microorganisms and Toxins
2 = Materials Processing
3 = Electronics
4 = Computers
5 = Telecommunications and Information Security
6 = Sensors and Lasers
7 = Navigation and Avionics
8= Marine
9 = Propulsion Systems, Space Vehicles, and Related Equipment
The second character identified the product group:
A. Systems, Equipment and Components
B. Test, Inspection and Production Equipment
C. Material
D. Software
E. Technology
If an item doesn’t fit into any of the ECCN code, the item is designated as EAR99. The majority of commercial goods falls into this category. In this case, the item can be exported without any license except to any embargoed of sanctioned countries (Cuba, Iran, North Korea, Sudan and Syria), to unauthorized party (this information can be found on the BIS website) or for any prohibited end-use.
Below is the list of the ECCN codes for the US-origin component of the XpertEye kit:
| XpertEye devices | ECCN Codes | |
| ODGR-7 | 5A002 | |
| Fujitsu | 5A002ENC-U | |
| DELL Lattitude E7250/E72 | 5A992.c | |
| Vuzix M300 | EAR99 |