What is the Commodity Control List?

Feb 15

The CLL lists export controls from the U.S department of Commerce with the Export Administration Regulations (EAR), covering items such as an export control classification number.

What is export control?

Export controls are regulations that govern the movement of goods, services, and technology across international borders. The Commodity Control List (CCL) is a list that outlines items that are subject to these controls as set forth by the U.S. Department of Commerce through the Export Administration Regulations (EAR). The CCL is divided into ten categories, each containing specific commodity classifications identified by an export control classification number (ECCN).

EAR-based export controls are designed to restrict exports of items that could contribute to the proliferation of weapons of mass destruction (WMD) or that could be used by terrorists. The CCL includes items that can be used in the development, production, and delivery of WMD, as well as items that can be used to support terrorist activities.

The CCL covers various items, including minerals, metals, chemicals, and microorganisms. It also includes equipment and software related to the production, use, or detection of WMD. In addition, the CCL covers items that can be used to produce or enhance WMD delivery systems, such as missiles and aircraft.

The CCL is regularly updated to reflect changes in technology and international security conditions. The most recent update to the CCL was published in December 2018.

Export controls on the items listed on the CCL are implemented through a licensing system administered by the U.S. Department of Commerce's Bureau of Industry and Security (BIS). Companies wishing to export items subject to the EAR must obtain a license from BIS before exporting the item.

The licensing process is designed to ensure that exports are consistent with U.S. national security and foreign policy interests. BIS considers a number of factors when reviewing license applications, including the end-use of the item and whether it could be used for WMD proliferation or terrorist activities.

Export licenses are typically valid for a specific period of time and may be restricted to a specific destination or end-user. Licensees must comply with all their license conditions, including maintaining records of their exports and making them available to BIS upon request.

Penalties for violating the EAR can be severe, including prison sentences and large fines. Violations can also result in the denial or revocation of export privileges, which can have a significant impact on a company's ability to do business internationally.

The Commodity Control List is an important tool in ensuring that exports from the United States do not contribute to the proliferation of weapons of mass destruction or support terrorist activities. Companies wishing to export items subject to the EAR must obtain a license from BIS, which reviews applications taking into account a number of factors related to national security and foreign policy interests. Penalties for violating export controls can be severe, so it is important for companies to understand their obligations under the EAR before exporting any items on the CCL.

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