ECCN.DEV by Cancelli

Questions people actually ask

Plain answers, each citing the rule behind it. None of them will tell you your classification, because that depends on facts a page cannot see. All of them will tell you what decides it.

ITAR or EAR, which one applies to me?

Two regimes, two agencies, and the wrong guess is expensive. The test is what the item is and what it was designed for, not what industry you are in.

What does EAR99 actually mean?

It means no Commerce entry describes your item. It does not mean you can ship it anywhere, and it is not a licence.

Can I hire an engineer who is not a U.S. citizen?

Yes. Export control regulates what you show them, not who you employ, and treating it as a hiring rule creates a different legal problem.

What is a deemed export?

Showing controlled technology to a foreign person inside the United States counts as exporting it to their country. Nothing has to ship.

Does encryption in my product trigger export controls?

Often yes, and it is a separate question from whatever else the product does. There are workable exceptions, and each has conditions you must actually meet.

Can I open source this?

Publishing is a release. Once it is public you cannot unpublish it, and the two regimes do not treat publication the same way.

Do I need an export licence?

Four things decide it: what the item is, where it is going, who is receiving it, and what they will do with it. Any one of them can require a licence on its own.

Do I have to register with DDTC?

Manufacturing a defense article can require registration even if you never export anything. Registration is annual, and it is not permission to export.

Can I keep controlled engineering data in the cloud?

Often yes, if the encryption is right and nobody else holds the keys. The provider's administrators are part of your access question.

When you want it for your own facts

The walkthrough asks eight questions and returns the obligations that apply to what you are actually building. Start there.