ECCN Country Chart: How to Determine EAR Export License Requirements Under 15 CFR Part 738

The ECCN Country Chart, officially designated as the Commerce Country Chart and codified at 15 CFR Part 738 Supplement No. 1, is a regulatory matrix published by the Bureau of Industry and Security (BIS) within the U.S. Department of Commerce. It cross-references the Reasons for Control associated with an Export Control Classification Number (ECCN) against foreign destination countries to determine whether an export or reexport license is legally required under the Export Administration Regulations (EAR).

What it is and who runs it

The Commerce Country Chart is administered and maintained by the Bureau of Industry and Security (BIS), an operating agency of the United States Department of Commerce, as described on the official page on 2026-11-14. Codified within the Export Administration Regulations at 15 CFR Part 738, the Country Chart serves as the central bridge connecting the technical specifications of dual-use commodities, software, and technologies to geopolitical trade controls. Under the statutory authority of the Export Control Reform Act of 2018 (ECRA, 50 U.S.C. §§ 4801-4852), BIS uses the chart to enforce multilateral agreements, protect national security, advance foreign policy objectives, and fulfill nonproliferation commitments.

In the architecture of U.S. export controls, determining whether an item may be exported without prior government authorization requires understanding how the Commerce Control List (CCL, 15 CFR Part 774 Supplement No. 1) interacts with foreign destinations. While the Commerce Control List (CCL) establishes the technical parameters and assigns an alphanumeric classification to an item, it does not stand alone. Rather, each entry on the CCL identifies one or more Reasons for Control. The Commerce Country Chart, located in Supplement No. 1 to Part 738, translates those Reasons for Control into country-specific licensing mandates across approximately 195 sovereign nations and territories.

The Country Chart is structured into horizontal column headers identifying eight major control categories, subdivided into 16 specific control columns, while vertical rows list destination countries alphabetically. Under 15 CFR § 738.3(b), destinations not individually listed on the chart that are dependencies, territories, or departments of an included nation take the licensing status of their governing state (for example, the Cayman Islands follow United Kingdom controls, and Liechtenstein is treated with Switzerland). However, the Country Chart does not govern all export decisions: comprehensive embargoes and special destination controls in 15 CFR Part 746 (such as those applying to Cuba, Iran, North Korea, Syria, and restricted regions of Ukraine, as well as comprehensive military sanctions on Russia and Belarus) override the chart entirely.

Eligibility (summary, with the official source)

Under 15 CFR § 738.1 and § 738.3, any person, enterprise, academic institution, or research facility subject to the jurisdiction of the United States that intends to export, reexport, or transfer (in-country) an item subject to the EAR must consult the Commerce Country Chart. Jurisdiction attaches not only to physical items manufactured in the United States, but also to foreign-produced items containing more than de minimis levels of controlled U.S. content (15 CFR § 734.4) and foreign direct products of certain U.S. technology or software.

For research universities, academic medical centers, and national laboratories, applying the Country Chart requires careful navigation of institutional compliance boundaries. A foundational principle in university research is the Fundamental Research Exclusion (FRE), defined in 15 CFR § 734.8. Under the FRE, information and software resulting from basic and applied research in science and engineering that is ordinarily published and shared broadly within the scientific community is excluded from the scope of the EAR. However, research administrators must recognize critical statutory limitations where the FRE does not apply:

• Physical Hardware and Commodities: The Fundamental Research Exclusion applies strictly to scientific information, data, and published results. It never applies to physical commodities. Shipping scientific instruments, lasers, specialized sensors, chemical reagents, or biological samples abroad always requires standard classification and Country Chart cross-referencing.
• Proprietary Vendor Technology: When a laboratory receives commercial technology, proprietary source code, or technical data under a non-disclosure agreement (NDA) or restricted material transfer agreement (MTA), that information is not public and does not qualify for the FRE. Releasing such proprietary technology to foreign national researchers requires Country Chart analysis under the deemed export rule (15 CFR § 734.13).
• Research Subject to Publication Restrictions: If a research agreement accepts restrictions on publication or permits a sponsor to approve foreign national participation, the project loses its fundamental research status entirely. All associated technology becomes subject to full EAR classification and Country Chart licensing rules.

Researchers and compliance officers can review broader classification foundations in the Export Control Classification guide, which outlines how initial jurisdictional boundaries between the Department of State and Department of Commerce are established.

What it funds or requires

The Commerce Country Chart does not disburse grant funding; rather, it establishes binding statutory requirements for export and reexport licensing. Codified in 15 CFR § 738.3(c) and Supplement No. 1 to Part 738, the chart organizes multilateral and unilateral trade controls into eight distinct Reason for Control designations comprising 16 control columns:

• Chemical and Biological Weapons (CB): Three columns (CB 1, CB 2, CB 3) based on Australia Group commitments, restricting dual-use production hardware (bioreactors, fermenters), chemical precursors, and pathogens.
• Nuclear Nonproliferation (NP): Two columns (NP 1, NP 2) pursuant to the Nuclear Suppliers Group (NSG), restricting items capable of supporting nuclear fuel cycle or weapons activities, including mass spectrometers and radiation shielding.
• National Security (NS): Two columns (NS 1, NS 2) under the Wassenaar Arrangement, protecting strategic advantages by controlling high-performance computing, advanced sensors, and lasers.
• Missile Technology (MT): One column (MT 1) under the Missile Technology Control Regime (MTCR), restricting rocket delivery hardware, unmanned aerial vehicles, propellants, and flight guidance systems.
• Regional Stability (RS): Two columns (RS 1, RS 2) under multilateral and unilateral policies preventing destabilizing military buildups, covering advanced optics, thermal imaging, and specialized dual-use components.
• Firearms Convention (FC): One column (FC 1) under the Inter-American Convention Against Firearms (CIFTA), restricting non-military firearms and optical sights in the Western Hemisphere.
• Crime Control (CC): Three columns (CC 1, CC 2, CC 3) under statutory human rights mandates, restricting law enforcement equipment and biometric identification systems.
• Anti-Terrorism (AT): Two columns (AT 1, AT 2) under unilateral statutory authorities, restricting sensitive dual-use items to designated state sponsors of terrorism.

When an exporter cross-references an ECCN against a destination country in Supplement No. 1 to Part 738, each cell contains either an ‘X’ or a blank space. Under 15 CFR § 738.4(a), the legal consequence of these entries is clear:

• An ‘X’ in the cell: Signifies that a license is affirmatively required for that specific reason for control to that destination. The item cannot be exported unless the exporter qualifies for an applicable License Exception under 15 CFR Part 740, or applies for and receives a formal export license issued by BIS.
• A blank cell: Signifies that no license is required under that specific reason for control for that destination. If every Reason for Control listed in the item’s ECCN has a blank cell for the destination, the export may proceed under the regulatory authorization ‘NLR’ (No License Required), provided that no General Prohibitions (15 CFR Part 736), end-user or end-use restrictions (15 CFR Part 744), or special embargoes (15 CFR Part 746) intervene.

Several categories of items fall outside the Country Chart’s standard matrix. Items designated as EAR99 classification are subject to the EAR but not listed on the CCL; they do not have an ECCN or Country Chart columns and ship under NLR to non-embargoed destinations. Conversely, certain sensitive ECCNs (such as 0A983, 5A001.f.1, 5D001, and 5E001.a) require a license to all destinations worldwide without reference to the Country Chart, as specified in 15 CFR § 738.3(a)(1). Items controlled for short supply under 15 CFR Part 754 are also governed independently of the Country Chart.

Application or compliance steps

Determining whether an export license is required using the CCL and the Country Chart follows a six-step compliance workflow codified at 15 CFR § 738.4 and § 732.3:

1. Classify the Item on the CCL: Determine the accurate 5-character ECCN for the commodity, software, or technology by reviewing technical parameters against Supplement No. 1 to Part 774. Consult the ECCN lookup guide for research equipment for detailed self-classification methods versus official BIS commodity classification requests.
2. Identify Applicable Reasons for Control: Review the ‘License Requirements’ section of the ECCN entry. Identify every Reason for Control (e.g., NS, NP, AT) and the exact column identifier (e.g., NS Column 1, NS Column 2, AT Column 1). Pay careful attention to paragraph subdivisions that limit controls to specific components.
3. Locate Destination Country: Open Supplement No. 1 to Part 738 and find the destination country in alphabetical order. Dependencies and territories take the licensing treatment of their governing nation pursuant to 15 CFR § 738.3(b).
4. Cross-Reference Each Control Column: Examine the cells where the destination row intersects with each applicable Country Chart column identifier. Under 15 CFR § 738.4(a)(1)(ii)(B), the exporter must evaluate every applicable reason for control, even if an earlier column already indicates that a license is required, to identify all potential license exceptions and determine the full scope of BIS review.
5. Evaluate Part 740 License Exceptions: If an ‘X’ appears in one or more columns, determine whether an affirmative License Exception under 15 CFR Part 740 overcomes each requirement. Check list-based exceptions in the ECCN entry (such as LVS for limited value shipments, GBS for Country Group B destinations, or TSR for restricted technology) and transaction-based exceptions (such as TMP for temporary exports under § 740.9 or BAG for personal baggage under § 740.14). Every affirmative ‘X’ must be satisfied by a valid exception.
6. Screen General Prohibitions and File via SNAP-R: If all columns are blank or all ‘X’ marks are overcome by valid exceptions, verify that General Prohibitions 4 through 10 do not apply. Confirm that no party appears on the Consolidated Screening List (such as the Entity List) and that the transaction involves no prohibited end-uses (15 CFR Part 744). If any ‘X’ cannot be overcome, submit an export license application to BIS via SNAP-R.

To illustrate this process in practice, consider a worked university research scenario based on the sample analysis in 15 CFR § 738.4(b):

A university laboratory plans to ship a high-precision digital streak camera to an international academic collaborator. The camera is valued at $22,000 and classified under ECCN 6A003.a.1. The ECCN heading indicates that the item is controlled for National Security reasons (NS Column 2) and Anti-Terrorism reasons (AT Column 1). Under ‘List Based License Exceptions,’ the ECCN specifies LVS: $5,000 and GBS: Yes.

• Scenario A (United Kingdom): Looking up the United Kingdom on the Country Chart, NS Column 2 is blank and AT Column 1 is blank. Because neither column contains an ‘X,’ no license is required under the Country Chart. The university verifies that the consignee is clear of restricted party lists and ships under ‘NLR.’
• Scenario B (South Africa): Looking up South Africa, NS Column 2 contains an ‘X,’ while AT Column 1 is blank. The ‘X’ mandates a license unless overcome by an exception. The camera’s value ($22,000) exceeds the LVS limit ($5,000). However, South Africa is listed in Country Group B (Supplement No. 1 to Part 740), making License Exception GBS available for eligible models, permitting shipment without a BIS license.
• Scenario C (Brazil): Looking up Brazil, NS Column 2 contains an ‘X’ and AT Column 1 is blank. If the camera model contains technical features excluded from GBS by an ECCN technical note, the university must submit a formal license application to BIS through SNAP-R.
• Scenario D (Temporary Field Research): If a faculty member temporarily transports the camera abroad for field measurements and retains personal custody, the university evaluates License Exception TMP (15 CFR § 740.9, ‘Tools of Trade’). Provided the destination is not an embargoed country and the item returns within 12 months, TMP authorizes the temporary export.

Typical timeline phases

Managing export compliance workflows involving the Commerce Country Chart requires structured planning across institutional and federal administrative milestones. Because regulatory and political conditions shift, institutions must track requirements dynamically as described on the official page on 2026-11-14:

• Phase 1: Institutional Classification and Review (1 to 5 business days): The research office identifies technical specifications, determines the ECCN, checks Supplement No. 1 to Part 738, and screens foreign entities against the Consolidated Screening List. If all columns are blank or a clear license exception applies, institutional clearance is issued immediately.
• Phase 2: Formal Classification Inquiry / CCATS (30 to 45 calendar days): If technical parameters are complex or self-classification is ambiguous, the institution submits a Commodity Classification request to BIS via SNAP-R under 15 CFR § 748.3. By regulation, BIS aims to issue a CCATS determination within 30 days.
• Phase 3: BIS License Application Interagency Review (30 to 90 calendar days): When an ‘X’ requires a license without exception, the institution submits an export license application. Under Executive Order 12981 and 15 CFR Part 750, the application enters interagency review:

1. Intake and Referral (Days 1–9): BIS logs the application in SNAP-R and routes it to reviewing agencies, including the Department of Defense (DTSA), Department of State, and Department of Energy.
2. Agency Substantive Review (Days 10–30): Reviewing agencies evaluate national security, nonproliferation, and regional stability factors based on the licensing policies in 15 CFR Part 742, submitting recommendations to approve, approve with conditions, or deny.
3. Interagency Escalation (Days 31–60+): If reviewing agencies disagree, the application escalates to the Operating Committee on Export Policy, and if necessary to the Advisory Committee on Export Policy.
4. Final Issuance: BIS issues the export license containing specific compliance conditions. Standard BIS licenses are valid for four years from the date of issuance pursuant to 15 CFR § 750.7(g).

Common mistakes

Export compliance audits of research organizations and commercial exporters routinely reveal six widespread operational errors when interpreting the Commerce Country Chart:

1. Stopping Analysis at the First Reason for Control: Exporters frequently find that an item is controlled for National Security (NS Column 2) and see that no ‘X’ appears for their destination, concluding that no license is required. However, they fail to check Regional Stability (RS) or Anti-Terrorism (AT) columns, which may contain an ‘X’ for that destination. Exporters must evaluate every applicable column; a single unresolved ‘X’ triggers a mandatory license requirement.
2. Confusing an ‘X’ with a Prohibitive Trade Embargo: Compliance staff sometimes misinterpret an ‘X’ as a blanket prohibition preventing any export to that country. An ‘X’ simply indicates that prior government authorization is required. Applications for many destinations are routinely approved under standard licensing policies established in 15 CFR Part 742, provided legitimate civilian research end-users are verified.
3. Searching the Country Chart for EAR99 Items: New compliance staff often spend hours attempting to locate ‘EAR99’ on the Commerce Country Chart. Because EAR99 items are not on the Commerce Control List, they have no Reason for Control codes and do not appear on the chart. EAR99 items ship under NLR to all destinations except embargoed countries (Part 746) or prohibited parties (Part 744).
4. Overlooking General Prohibitions and End-User Screening: Assuming that a blank cell on the Country Chart guarantees a green light to ship without further scrutiny is a severe compliance violation. General Prohibitions 4 through 10 (15 CFR Part 736) apply regardless of Country Chart entries. If the foreign consignee is listed on the BIS Entity List, Unverified List, or OFAC Specially Designated Nationals (SDN) list, the export requires an authorization that cannot be bypassed by Country Chart NLR status.
5. Misapplying the Fundamental Research Exclusion to Physical Exports: Academic researchers frequently assume that because their project involves basic research, laboratory equipment purchased with grant funds can be shipped abroad to collaborators without export clearance. Physical items never qualify for the FRE; hardware is subject to standard CCL classification and Country Chart licensing.
6. Ignoring Deemed Export Implications for Foreign National Personnel: Research institutions often examine the Country Chart only when packaging a physical box for international freight, forgetting that transferring controlled source code or technical data to a foreign national graduate student, postdoc, or visiting scholar within a U.S. university laboratory constitutes a ‘deemed export’ under 15 CFR § 734.13. The researcher’s country of citizenship must be screened against the Country Chart for technology controls (Product Group E).

Related programs

The Commerce Country Chart is one component of a broader multi-agency federal export control framework. Research organizations must understand how the EAR Country Chart compares to related regulatory systems, as summarized in the comparison below.

Researchers comparing jurisdictional frameworks should review the detailed ITAR vs. EAR side-by-side comparison for comprehensive analysis of dual-use versus defense article controls.

Compliance Framework	Governing Authority	Primary Regulatory Scope	Destination Assessment Mechanism	Impact on Academic Research
Commerce Country Chart (EAR)	Bureau of Industry and Security (15 CFR Part 738)	Commercial and dual-use commodities, software, and technology on the CCL	16 Reason for Control columns cross-referenced against 195 destinations in Supp. No. 1 to Part 738	Governs physical shipments of lab equipment, deemed exports of proprietary tech, and field research tools
U.S. Munitions List (ITAR)	Directorate of Defense Trade Controls (22 CFR Parts 120-130)	Defense articles, military technologies, defense services, and space items	Categorical country policies under 22 CFR § 126.1; virtually all non-exempt exports require licenses	Strict controls on defense-funded projects; fundamental research exclusion does not apply to defense services
OFAC Sanctions Programs	Office of Foreign Assets Control (31 CFR Parts 500-599)	Financial transactions, economic embargoes, and services to sanctioned destinations or parties	Comprehensive country sanctions (Cuba, Iran, Syria) and targeted regimes without ECCN cross-referencing	Prohibits providing services, academic training, or funding to sanctioned regions regardless of ECCN status
BIS SNAP-R CCATS System	Bureau of Industry and Security (15 CFR § 748.3)	Official agency determination of an item’s technical ECCN or EAR99 classification	Advisory classification finding that provides the confirmed ECCN needed to use the Country Chart	Resolves ambiguity when self-classifying high-tech laboratory equipment, customized sensors, or novel software
Consolidated Screening List (CSL)	Interagency (Commerce, State, Treasury)	Parties subject to trade restrictions (Entity List, Denied Persons, SDN, Unverified List)	Name and entity-based screening tool that overrides NLR authorizations and license exceptions	Mandatory screening before collaborating with foreign research institutions, foreign scholars, or foreign co-authors

The data table below provides a detailed structural breakdown comparing the eight Reason for Control codes that govern the Country Chart columns.

Frequently asked questions

How does an ECCN reason for control map to the Commerce Country Chart?

Every Export Control Classification Number (ECCN) on the Commerce Control List includes a ‘License Requirements’ section listing one or more Reasons for Control (such as National Security, Nuclear Nonproliferation, or Anti-Terrorism) alongside specific column identifiers (such as NS Column 1 or AT Column 1). The exporter locates the destination country on the Commerce Country Chart (15 CFR Part 738 Supplement No. 1) and checks the intersecting cell for each identified column. If an ‘X’ appears in that cell, a license is required for that specific control reason unless overcome by an applicable Part 740 license exception.

What does an X in the Commerce Country Chart mean?

An ‘X’ in a Commerce Country Chart cell indicates an affirmative export license requirement for that reason for control to that specific destination. It does not signify an outright trade ban or embargo; rather, it establishes that the exporter cannot ship under ‘NLR’ (No License Required). The exporter must either qualify for an affirmative License Exception under 15 CFR Part 740 (such as LVS, GBS, or TMP) or apply for and obtain a validated export license from the Bureau of Industry and Security prior to shipment.

Can an item be exported under NLR if the Country Chart shows an X?

No. If any applicable Reason for Control column contains an ‘X’ for the destination country, the export cannot be authorized as ‘NLR’ (No License Required). The exporter must either identify a valid License Exception under 15 CFR Part 740 that completely overcomes the ‘X’ (and all other affirmative ‘X’ entries for that item), or submit a formal license application to BIS. Shipping an item under NLR when an ‘X’ governs the transaction without a valid exception constitutes a violation of the Export Administration Regulations.

Does the Fundamental Research Exclusion eliminate the need to check the Country Chart?

No. The Fundamental Research Exclusion (FRE, 15 CFR § 734.8) applies exclusively to scientific information, technical data, and research results that are published and broadly shared within the academic community. The FRE never applies to physical commodities, laboratory equipment, materials, or biological specimens. Furthermore, proprietary third-party data received under non-disclosure agreements is not exempt. Any physical export of lab equipment or transfer of proprietary technical data requires full ECCN classification and Country Chart cross-referencing.

How do deemed exports relate to the Commerce Country Chart?

Under 15 CFR § 734.13, releasing controlled technology or source code to a foreign national within the United States is deemed an export to the foreign national’s home country of citizenship or permanent residency. To determine whether a deemed export license is required, the institution must identify the ECCN of the technology (Product Group E on the CCL), determine its Reasons for Control, and cross-reference the foreign national’s home country on the Commerce Country Chart. An ‘X’ in the relevant column requires either an applicable license exception (such as TSR) or a BIS deemed export license before granting lab access.

Sources

• Bureau of Industry and Security, U.S. Department of Commerce. (2026-11-14). 15 CFR Part 738: Commerce Control List Overview and the Country Chart. Legal Information Institute / Electronic Code of Federal Regulations. https://www.law.cornell.edu/cfr/text/15/part-738
• Bureau of Industry and Security, U.S. Department of Commerce. (2026-11-14). Supplement No. 1 to 15 CFR Part 738: Commerce Country Chart. Legal Information Institute / Electronic Code of Federal Regulations. https://www.law.cornell.edu/cfr/text/15/appendix-Supplement_No_1_to_part_738
• Bureau of Industry and Security, U.S. Department of Commerce. (2026-11-14). 15 CFR Part 732: Steps for Using the EAR. U.S. Department of Commerce. https://www.bis.gov/regulations/ear/732
• Bureau of Industry and Security, U.S. Department of Commerce. (2026-11-14). 15 CFR Part 740: License Exceptions. U.S. Department of Commerce. https://www.bis.gov/regulations/ear/740
• Bureau of Industry and Security, U.S. Department of Commerce. (2026-11-14). 15 CFR Part 742: Control Policy – CCL Based Controls. U.S. Department of Commerce. https://www.bis.gov/regulations/ear/742
• Bureau of Industry and Security, U.S. Department of Commerce. (2026-11-14). 15 CFR Part 734: Scope of the Export Administration Regulations. Legal Information Institute / Electronic Code of Federal Regulations. https://www.law.cornell.edu/cfr/text/15/part-734