The Commerce Control List (CCL) is the backbone of U.S. export controls, managed by the Bureau of Industry and Security (BIS). It is a list of categories and specific items that require a license to be exported to certain countries.
For heavy equipment exporters, the CCL is the filter that determines whether your shipment is a standard commercial transaction or a potential national security risk.
Dual-Use Goods: Hidden Risk
Most heavy machinery is considered Dual-Use. A bulldozer is designed to move dirt for a highway (civilian use), but it can also be used to build tank traps or fortify bunkers (military use). While standard construction equipment is usually loosely controlled, specialized machinery can trigger red flags on the CCL.
- High-tech drills: Drilling rigs with advanced sensors or diamond-tipped heads might be restricted because they can be used for nuclear proliferation activities.
- Off-road trucks: Certain heavy-duty, multi-axle trucks designed for extreme terrain can be classified as missile-carriers.
- GPS & tech: The GPS receivers and automated grading systems inside modern excavators might be controlled if they use military-grade encryption or accuracy.
ECCN (Export Control Classification Number)
To navigate the CCL, you need to classify your machinery with an ECCN. This is a 5-character alphanumeric code (e.g., 8A992).
EAR99
This is the classification you want. It means your item is subject to regulations, but is not on the specific control list. Most standard Caterpillar, Komatsu, or John Deere equipment is EAR99. It can go to most places without a special license (except embargoed nations like Cuba, Iran, and North Korea).
Specific ECCN
If your machine has a specific ECCN (like 0A919 for military-derived commodities), you must check the Country Chart to see if you need a license for your specific destination.
Catch-All Controls
Even if your item is EAR99, the CCL rules have a Catch-All provision. If you know (or should know) that your harmless water pump is going to be used in a chemical weapons facility, you cannot ship it. Ignorance is not a defense. You must screen your customers against the Denied Persons List to ensure you aren’t violating CCL regulations.