DCAA Compliance Blog

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The Commerce Control List & Export Administration Regulations

Posted by Mike Anderson on Wed, Oct 15, 2014 @ 03:31 PM

When a company exports a commercial product from the United States, it must first determine if an export license is required from the Department of Commerce. The controls for exporting items (an item might be a product or a service in the form of some knowledge) is controlled by the US Department of State, specifically the Bureau of Industry & Security (BIS). The Federal Government takes an interest in what is being exported, where it might go and how it might be used. Obviously, the government doesn’t want US technology to be exported to a region or country where this technology or product could be used against the United States or to cause harm to the US or it citizens. It is interesting to note that all exported items are controlled in this fashion, regardless of value and regardless of whether they are sold or given away.

BIS identifies two types of items, ones that are purely commercial and “dual use” items that can have both commercial and military use. Both of these types of items fall under the Export Administration Regulations (EAR) that are implemented and enforced by BIS. The BIS lists all items on a Commerce Control List (CCL) along with license requirements, license exceptions and a list of items controlled. The CCL is divided into 10 categories. Each category is subdivided into 5 product groups:

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Topics: EAR, CCL