Export Compliance

Export Control Classification Number (ECCN)

Different countries and trade zones have established limitations on exporting certain goods, technolo­gy or services. A very common classification of such items is “dual-use” – items, as they have both commercial and military or proliferation applications. Note that also purely commercial items without an obvious military use may also be subject to these export restrictions.

Dual use goods are products and technologies normally used for civilian purposes but which may have military applications. Most countries therefore restrict the export of certain commodities and technologies, and require an export license from the government prior to an export.

There are several international arrangements among countries, which seek to harmonize lists of dual-use (and military) technologies to control. These include the Nuclear Suppliers Group, the Australia Group (chemical and biological technologies), the Missile Technology Control Regime (focusing on delivery systems for weapons of mass destruction) and the Wassenaar Arrangement (covering conventional arms and dual-use technologies).

The Export Control Classification Number (ECCN) classifies the level of export control for any product, software and technology that is exported from the member states of the Wassenaar Arrangement.

The ECCN classification that applies to any specific item is determined by referring to a table that is issued for the United States by the U.S. Department of Commerce Bureau of Industry and Security (BIS) and for the European Union by Regulation 428/2009. (cf.: Wikipedia)

EU member states having established their national laws and regulations, for example for Germany this is the Aussenwirtschaftsgesetz and Aussenwirtschaftsverordnung.

Toradex makes no representation or warranty as to the accuracy or reliability of the classifications lis­ted in this Classification Chart below. Any use of such classifications by the customer is at the users’ own risk. It is the legal responsibility of the exporter to comply with the Export Administration Regula­tions (EAR).

The following classifications are based on unmodified products in original condition, as shipped by Toradex and are valid for the whole respective product family unless indicated separately:

Remarks

1. 5A992.c: With exception of exports and reexports to embargoed or sanctioned countries, to a party of concern, or in support of a prohibited end-use, Mass Market products may generally be exported without further license in respect to EAR. For "de minimis" calculations please check https://www.bis.doc.gov/index.php/forms-documents/pdfs/1382-de-minimis-guidance.
2. EAR99: Not controlled by other categories, products may generally be exported without further license. A license may, however, be required for exports and reexports to embargoed or sanctioned countries, to a party of concern, or in support of a prohibited end-use. For details, please check the websites of the BIS, in particular https://www.bis.doc.gov/index.php/licensing/commerce-control-list-classification/export-control-classification-number-eccn about EAR99 and https://www.bis.doc.gov/index.php/forms-documents/pdfs/1382-de-minimis-guidance about "de minimis" calculations.