The U.S. Department of Commerce has instituted a new regulation for the export, re-export, and in-country transfer of products to the People’s Republic of China, Russia, and Venezuela. These new controls enable the U.S. government to more closely monitor exports, re-exports, and in-country transfers of certain items, broadening the scope of export-controlled items to include electronic and telecommunications equipment. These changes include but are not limited to: PC’s, mobile devices, smart watches, heart monitors, night vision goggles, and so on. These new controls apply to all shipments to these countries even if there is no military end use for the products, and is effective as of June 29. 2020.
What is changing?
Shipments destined for China, Russia, or Venezuela must now include:
- Your ITN; which is proof that you filed the EEI using the AES.
- The ECCN or EAR99 number for each line item on the Commercial Invoice or Shipper’s Letter of Instruction.
In the past only shipments valued at $2,500 USD or more required an EEI filing, now regardless of value, you must file and capture either the ECCN or EAR99 (whichever applies) against each line item.
Why the Change?
This change enables the U.S. government to more closely monitor exports, re-exports, and in-country transfers of certain items to China, Russia, and Venezuela. Specifically this change broadens what electronic and telecommunications equipment is included in the United States CCL. You may click here to view the full CCL on the U.S. Department of Commerce website.
Definition of Terms
This article uses terminology you may not be familiar with. Several important terms are defined below:
| Term | Definition |
| AES | US Census’ Automated Export System where export declarations are made. |
| CCL | The Commerce Control List (CCL) is a list of categories and product groups that determine whether an export license is needed from the U.S. Department of Commerce for you to export such products out of the United States. |
| EAR99 | The majority of Commercial products are classified this way, and indicates that a particular item is subject to the Export Administration Regulations (EAR), but not listed with a specific ECCN on the Commercial Control List (CCL). |
| ECCN | An Export Control Classification Number used to classify goods, technology and software to determine whether an export license is required. |
| EEI | Electronic Export Information submitted to the AES as part of the export declaration. |
| ITN | Internal Transaction Number. Confirmation that the AES EEI was accepted and also the filer’s proof of filing. |