- 1Controlled goods require ECCN or USML classification before any AES filing
- 2Both EAR and ITAR items need license numbers or exception codes in the EEI
- 3Misclassification is a violation — not just a rejection
- 4Run a denied party screening before every controlled goods export
Controlled Goods Require More Than a Standard EEI Filing
Exporting goods subject to U.S. export controls is not like filing a standard commercial shipment. The AES filing for controlled goods must include specific license data, classification codes, and authorization references. Errors are not just rejections. They are potential violations with serious legal consequences.
If your export falls under EAR or ITAR, this guide covers what you need to know before filing.
What Are Controlled Goods?
Controlled goods are items regulated by U.S. export control laws. The two primary frameworks are the Export Administration Regulations (EAR), administered by the Bureau of Industry and Security (BIS), and the International Traffic in Arms Regulations (ITAR), administered by the Directorate of Defense Trade Controls (DDTC).
Controlled goods include dual-use technology, defense articles, encryption products, and sensitive commercial equipment. Even everyday items can be controlled depending on destination country and end user.
Classifying Items: ECCN and USML
Every controlled item requires a classification.
Items under EAR are assigned an Export Control Classification Number (ECCN). Items under ITAR are listed on the United States Munitions List (USML). Both classification systems determine which export licenses or license exceptions apply.
Misclassifying an item is a violation in itself. Use BIS's Commerce Control List and DDTC's USML to verify classification before filing.
Obtaining Export Licenses
If no license exception applies, you must obtain an export license before shipping.
BIS SNAP-R vs. DDTC DECCS
BIS licenses are applied for through the Simplified Network Application Process Redesign (SNAP-R). DDTC licenses for ITAR-controlled items are applied for through the Defense Export Control and Compliance System (DECCS). Processing times vary. Apply well in advance of your shipment date.
AES Filing Specifics for Licensed Goods
When filing EEI for controlled goods, include:
- ECCN or USML category
- License type (specific license number, license exception code, or NLR for No License Required)
- Authorized dollar value and quantity under the license
- Any required end-user or end-use certifications referenced in the license conditions
Incomplete license data in the EEI filing triggers immediate AES rejection and potential enforcement review.
Mandatory Data in EEI for Controlled Exports
Beyond standard fields, controlled goods filings require:
- License code and license number or exception symbol
- ECCN for EAR items, USML category for ITAR items
- Accurate party information matching the license terms
- Commodity description matching the licensed item description
Every field must match the license. Discrepancies between the EEI and the license are a compliance violation.
Compliance Pitfalls to Avoid
The most common ITAR AES requirements errors include using the wrong license exception, omitting the ECCN, entering an inaccurate value, and failing to screen the end user against denied party lists before filing. Run a denied party screening before every controlled goods export.
Partner with Licensed Filers for Controlled Goods
Controlled goods exports carry enforcement risk that goes beyond a rejected filing. A professional filer familiar with EAR and ITAR requirements ensures the EEI is complete, accurate, and compliant before submission.
Contact us at /contact to discuss controlled goods filing requirements. Call 833-AES-FILE (833-237-3453).