Before you can legally export many commercial or dual-use goods from the United States, you need to determine whether an export license is required. This process is governed by the Export Administration Regulations (EAR) and enforced by the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce.
One of the most important tools in this process is the Commerce Country Chart, which helps exporters determine if a license is needed based on the destination country and the reasons for control tied to a product’s classification.
But here’s the catch: The Commerce Country Chart is only one part of a multi-step license determination process. To use it correctly, you must first:
This article walks you through step three: how to read and apply the Commerce Country Chart so you can quickly and confidently determine if your export needs a license.
If you're unsure about ECCNs, reasons for control or how to start the process, download our free guide: How to Determine If You Need an Export License before you keep reading.
Note: If you don't know if your goods fall under the EAR or who has jurisdiction over your exports, read the blog post, Determining Export Controls Jurisdiction and Classification: ITAR and EAR Order of Review.
The Commerce Country Chart is a reference table published by BIS that helps determine whether an export license is required based on the destination country and the reasons for control listed on a product’s ECCN.
You can find the current chart in Supplement No. 1 to Part 738 of the EAR, which lists nearly every country in the world in rows, and control codes (like NS, AT, CB, MT, etc.) in columns.
Each ECCN on the CCL includes one or more reasons for control—such as National Security (NS) or Anti-Terrorism (AT)—and tells you which control column(s) apply. You then look up the destination country in the chart to see if there’s an "X" under that column.
This chart is essential to navigating U.S. export regulations, but it only works if you've already identified your ECCN and the correct reasons for control.
In the next section, we’ll walk through an example to show exactly how this process works in practice.
Conclusion: Because NS Column 2 applies and Algeria has an “X” in that column, you must obtain an export license for this item—even though AT does not apply.
The Commerce Country Chart helps determine license requirements based on the destination country and your product’s reasons for control, but it’s not the full picture.
Even if the chart shows that no license is required, you may still need one based on the end use of your item or the end user receiving it. These controls are outlined in Part 744 of the EAR, and they exist to prevent U.S. exports from contributing to the development of:
These rules are enforced regardless of ECCN or destination. If you need help screening the parties in your export transaction, register for a free trial subscription of our Restricted Party Screening Software here.
Not every export requires an ECCN or appears on the CCL. In fact, many commercial items fall into a catch-all category known as EAR99.
EAR99 is a classification for items that are subject to the EAR but are not specifically listed on the CCL. These items are generally considered low risk and typically do not require a license—unless:
NLR stands for No License Required, and it’s commonly used in two scenarios:
When you file through AES, the license type “C33” is used to indicate an NLR shipment. This is not a license, but it documents that a license wasn’t required under the EAR.
Determining whether you need an export license isn’t just about the product or the destination—it’s about the full context of the transaction. You need to consider:
Even when an item seems low risk, like those classified as EAR99, you’re still responsible for screening parties and understanding potential red flags.
This article focused on just one part of the puzzle: using the Commerce Country Chart to interpret reasons for control and country-specific license requirements. If you're unsure about ECCNs, license exceptions or restricted party screening, be sure to check out our free guide: How to Determine If You Need an Export License.
And if you’re tired of spending hours manually reviewing the CCL and Commerce Country Chart, let Shipping Solutions Trade Compliance Software do it for you.
With our tools, you can:
Try our Trade Compliance Software tools here for free.
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