STEP 1

Survive the USML

ITAR § 120.11 is mandatory. If it is a defense article — including a USML catch-all — stop. Open the ITAR atlas. The CCL is the wrong map.

STEP 2

Confirm it is subject to the EAR

§ 734.3. U.S. origin, in the U.S., over-de minimis, or a foreign-direct product. Published and fundamental-research exclusions live in 734.7 / 734.8.

STEP 3

Pick the CCL category and product group

Supp. No. 4 steps 1–2. Category 0–9, then A/B/C/D/E. Do not analogize from a heading in another group.

STEP 4

600 series and 9x515 first

Enumerated 600-series and 9x515 paragraphs beat other ECCNs in the same category. These are former USML articles with ITAR-like licensing posture.

STEP 5

Catch-all and specially designed

If no enumerated paragraph hits, read the .x catch-all and run the § 772.1 specially designed (a)/(b) tests.

STEP 6

Walk the remaining ECCNs, then EAR99

If still unclassified, walk the product group from the top. If nothing lists it, it is EAR99 — still subject to 744 and 746.