Classifying your products correctly (according to the U.S. control lists) is the most critical aspect of your corporate export control process, particularly in light of the ongoing export control reforms and the migration of many items from the Department of State’s jurisdiction on the U.S. Munitions List (USML) to the Department of Commerce’s Commerce Control List (CCL) to form the “600 series.”
CTP has several engineers on staff who were former licensing officers at BIS, enabling us to first determine Commodity Jurisdictions (CJ), then provide Export Control Classification Number (ECCN) or International Traffic in Arms Regulations (ITAR) categories. We often work on large projects (10,000+ items) doing high volume tech data transfers, as well as small but highly technical classification tasks where we do the research (using data sheets and expert interviews), assist with discrete government inquiries, and then write/edit the specific classification rationale to address the logic of the Export Administration Regulations (EAR).
In summary, CTP provides a range of product classification services, including:
- Determine or verify the correct jurisdiction for the item, that is, does an item belong on the CCL or the USML? This is an important topic recently, given the sweeping export control reforms.
- Once jurisdiction over the product is established, determine the proper ECCN or ITAR Category for the item
- Compile all company items into a Product or Technology Classification Matrix
- Research the availability of EAR exceptions or ITAR exemptions
- Determine the Schedule B numbers and HTS Codes
Accuracy is assured, since several of our experts were authors of key processes and procedural rulings in the development of the U.S. export control system and they continue to stay abreast of technical advances, U.S committee rulings, and changes at the international export control regimes. Our primary strength is in dual-use export controls, but we are also adept in the classification and licensing of military items.
If you need a RUSH classification, check out our “Just-in-Time” Classification service.
Note: Export control reforms are clearly transforming the classification landscape, shifting many items from the USML to the less restrictive CCL. Companies are scrambling to determine the new jurisdictions and classifications and find out how these changes will affect them. The good news is that the CCL is more lenient but the short term downside is that companies have to learn how to classify items using the CCL, research the available exceptions, and then submit their license application through BIS instead of DDTC.