Item Classification and Deemed Exports

The Export Control Officer works with department leadership to gather sufficient information to determine with an item, software, or information is controlled under the Export Administration Regulations (EAR). Generally, all items of U.S. origin or items physically located in the U.S. are subject to the EAR.

The EAR requires a license for the export of a wide range of items, but only items listed on the Commerce Control List (CCL) require an export license prior to exportation or prior to sharing that item or information with a foreign person.

Items not listed on the CCL are designated as EAR99 items and generally can be exported or shared with a foreign person without a license, unless:

  • The export is to a sanctioned or embargoed country
  • The export is to a foreign person from a sanctioned or embargoed country

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