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.