BIS Commodity Classification Submissions

The Bureau of Industry and Security (“BIS”) is the concerned regulatory body for all “Dual-Use Goods” that are being (1) permanently export, (2) temporarily exported, or (3) temporarily imported for transshipment. Dual-Use Goods are listed on BIS’s Commerce Control List (“CCL”), which is found within BIS’s Export Administration Regulations (“EAR”). The CCL is organized by a classification system of numbers known as Export Classification Control Numbers(“ECCNs”).

It is the responsibility of the U.S. Principal Party of Interest (“USPPI”)/U.S. Exporter to ensure that proper ECCN designations are made against their goods. This can be difficult, so BIS offers Commodity Classification support for proper ECCN selection. In some cases, Commodity Classification requests lead to USPPIs receiving welcomed news that their goods are “EAR99”— the lowest level of control that often does not require licensing authorizations for most destinations.

DTGruelle is experienced in BIS Commodity Classification request submissions and can provide 3rd party requests on our clients’ behalf. DTGruelle also offers lateral support in:

• The appropriate strategies and procedures that make for a well-executed Commodity Classification request.

• Drafting comprehensive Commodity Classification request packets.

• Self-determination of ECCNs for Dual-Use Goods and Technology.

• Regulatory interpretations of the EAR.