ECCN Classification and the Commerce Control List: Category 3, Entries and ECCN vs HTS

What changed: Rewritten around the Commerce Control List itself: how it is organized, our count of Category 3's 78 entries, one entry read line by line against the Country Chart, and why the same HTS code can carry different ECCNs.

The short answer

ECCN classification is the process of finding the Commerce Control List (CCL) entry, or ECCN, whose technical parameters an exported item meets, or confirming that none does, which makes it EAR99. The CCL has 10 categories, each split into five product groups, and Category 3 (Electronics) alone holds 78 ECCN headings in the current eCFR text. An ECCN is not an HTS code: the HTS sets import duty, the ECCN decides export licensing. For an electronics manufacturer whose broker supplied HTS codes for 20,000 parts, every ECCN is a separate classification.

Next step:Try the Classification Researcher on one product

In this post
  1. What is ECCN classification?
  2. How is the Commerce Control List organized?
  3. What does CCL Category 3 cover?
  4. How do you read a Commerce Control List entry?
  5. Is an ECCN the same as an HTS code?
  6. What changed on the Commerce Control List in 2025 and 2026?
  7. Where does GingerControl's Export Control Classifier fit?
  8. Where this fits in your export compliance workflow
  9. References

I build export control classification software at GingerControl, so I spend a lot of time inside the CCL's legal text. This post is about reading that list: how it is laid out, what one Category 3 entry says line by line, and why the HTS code your broker gave you does not tell you the ECCN. If you need the lookup routes (manufacturer, Interactive CCL search, a BIS request), they are in my guide to finding an ECCN number; if your item matches nothing, read what EAR99 means and when it still needs a license.

What is ECCN classification?

ECCN classification is the step that matches an item subject to the Export Administration Regulations (EAR) to an Export Control Classification Number on the Commerce Control List, or designates it EAR99 when no ECCN describes it [3]. BIS describes ECCNs as "five character alpha-numeric designations used on the Commerce Control List to identify items for export control purposes" [1]. The ECCN then points to the reasons for control and, through the Country Chart, to the destinations that need a license [2].

Three things make it different from import classification:

  • It is decided by technical parameters, such as clock frequency, power, resolution or processing performance, not by what the product is called or what it is made of.
  • Hardware, software and technology are classified separately. A chip, its firmware and its design data can sit in three different ECCNs [2].
  • The exporter owns the answer. BIS lets you self-classify, rely on the manufacturer, or ask BIS for an official classification [1].

How is the Commerce Control List organized?

The Commerce Control List is organized into 10 categories, each divided into the same five product groups, and every ECCN's first two characters tell you where it sits [2]. The CCL itself is Supplement No. 1 to Part 774 of the EAR; the structure is set out in 15 CFR 738.2.

CategoryCoversProduct groups (same in every category)
0Nuclear materials, facilities and equipment, and miscellaneousA: equipment, assemblies and components
1Materials, chemicals, microorganisms and toxinsB: test, inspection and production equipment
2Materials processingC: materials
3ElectronicsD: software
4ComputersE: technology
5Telecommunications (Part 1) and information security (Part 2)
6Lasers and sensors
7Navigation and avionics
8Marine
9Aerospace and propulsion

The last three digits carry the reasons for control, by band: 000 to 099 national security, 100 to 199 missile technology, 200 to 299 nuclear nonproliferation, 600 to 699 the "600 series" of former munitions items, and 990 to 999 anti-terrorism, regional stability and UN sanctions, among others [2]. So 3A001 is Category 3, group A, national security band; 3A991 is the same category and group, in the anti-terrorism band. My guide to finding an ECCN number counts every ECCN by those bands.

The order you read the list in is fixed too. The order of review in Supplement No. 4 to Part 774 says: confirm the item is not described on the U.S. Munitions List, find the likely category and product group, check the 600 series and 9x515 entries first because they "trump other ECCNs," then review each other ECCN in the group, and designate the item EAR99 only if no ECCN in any category describes it [4]. If your parts might be defense articles, start with ITAR vs EAR before the CCL.

What does CCL Category 3 cover?

CCL Category 3 covers electronics: electronic components and equipment, semiconductor manufacturing and test equipment, electronic materials, and the software and technology for all of them. By GingerControl's count of the eCFR text current to October 29, 2026, Category 3 has 78 ECCN headings, and 34 of them sit in the software (D) and technology (E) groups, not with the hardware [3].

34 of Category 3's 78 ECCNs control software or technologyECCN headings in CCL Category 3 (Electronics), by product group

Source: GingerControl count of ECCN headings in Category 3 of Supplement No. 1 to Part 774, eCFR current as of October 29, 2026

See the data
Product groupECCN headings
A: Equipment, assemblies, components25
B: Test, inspection, production equipment9
C: Materials10
D: Software17
E: Technology17

The entries an electronic components maker meets most often:

ECCNWhat it covers (heading, shortened)Reasons for control
3A001Electronic items: integrated circuits, microwave components, electronic assemblies and more, against detailed thresholdsNS, RS, MT, NP, AT
3A002General purpose electronic assemblies, modules and equipment, such as certain recorders, signal generators and analyzersNS, MT, AT
3A090Integrated circuits: advanced computing chips above 'total processing performance' thresholds (3A090.a, .b) and high bandwidth memory (3A090.c)RS, AT
3A991Electronic devices and components not controlled by 3A001, such as microcontrollers above 25 MHz and larger memoriesAT
3A992General purpose electronic equipment not controlled by 3A002RS, AT
3B001 / 3B993 / 3B994Equipment for making semiconductor devices, including 3B993 and 3B994 (specified and advanced-node equipment), added by a rule published December 5, 2024NS, RS, AT / RS, AT / RS, AT
3D991 / 3E991Software and technology for the electronic items in 3A991 and similar entriesAT

Source: eCFR, Supplement No. 1 to Part 774, current as of October 29, 2026 [3]; 3B993 and 3B994 from 89 FR 96790 [7].

Two counts from the same text tell you how Category 3 behaves. Anti-terrorism (AT) appears in 76 of its 78 headings, and national security (NS) in 40. Only six headings are AT-only: 3A991, 3B991, 3B992, 3C992, 3D991 and 3E991 [3]. Those six basket entries are where many commercial chips land, which matters because AT-only items need a license for far fewer destinations than NS items.

Quotable insight: In CCL Category 3, 34 of the 78 ECCN headings control software or technology, not hardware (GingerControl count, eCFR current to October 29, 2026). An electronics exporter that classifies only its parts in group 3A has classified less than half of what the category can reach: the firmware it ships and the design data it shares with an overseas plant are separate classifications, in 3D and 3E.

How do you read a Commerce Control List entry?

You read a CCL entry in four parts, in order: the heading, the License Requirements, the License Exceptions, and the List of Items Controlled, then you take each reason for control to the Country Chart [2]. 15 CFR 738.2(d)(2) defines those four sections. Here is 3A001, the entry most electronic components get tested against first, as it reads on the eCFR current to October 29, 2026 [3]:

Part of the entryWhat 3A001 saysWhat it tells you
Heading"Electronic items as follows (see List of Items Controlled).""See List of Items Controlled" at the end means the Items paragraph is the exclusive list [2]
Reason for ControlNS, RS, MT, NP, ATEvery reason that can apply to some paragraph of the entry
Control(s) and Country Chart"NS applies to entire entry", NS Column 2; NS Column 1 for certain MMIC amplifiers and microwave transistors; MT, NP and RS for named paragraphs only; "AT applies to entire entry", AT Column 1Which Country Chart column each paragraph is checked against
License Requirements noteSee 15 CFR 744.17 for microprocessors of 5 GFLOPS or more with a 32-bit or wider arithmetic logic unitA rule outside the Country Chart that can still require a license
List Based License ExceptionsLVS, GBS and the others, with exclusions by paragraphWhether a license exception may cover the export
List of Items ControlledParagraphs a to i, plus z, with the technical parametersWhere your datasheet is tested

Then the Country Chart in Supplement No. 1 to Part 738. For a components maker shipping to distributors in China, Germany and India, the chart current to October 29, 2026 reads like this [5]:

Country Chart columnChinaGermanyIndia
NS 1XXX
NS 2X
RS 2X
AT 1

An X means a license is required for items controlled under that column, unless a license exception applies [5]. So a part caught by 3A001's "entire entry" NS Column 2 line needs a license for China but not, on that line, for Germany or India; the 3A001.b.2 MMIC amplifiers and b.3 microwave transistors under NS Column 1 (other than those for civil telecommunications use) need one for all three. A 3A991 part, controlled only under AT Column 1, needs no license on the chart for any of the three, though 15 CFR 744.21 still requires one for a military end use or end user in China [15].

The Country Chart is only the list-based half. End-use and end-user rules in Part 744, including the Entity List, can require a license for any ECCN or EAR99 item [4]. BIS's rule extending end-user controls to affiliates of certain listed entities (90 FR 47201) is stayed until November 9, 2026, and applies from November 10 unless BIS extends the stay; the Federal Register showed no extension as of November 2, 2026, so check it before you rely on either state [9]. Screen the distributor in Shenzhen as carefully as you classify the part; the denied-party screening guide covers that half.

Is an ECCN the same as an HTS code?

No. An ECCN comes from the Commerce Control List and decides export licensing; an HTS code comes from the Harmonized Tariff Schedule and sets U.S. import duty and trade statistics, and BIS says an ECCN "is distinct from and entirely unrelated to either a Schedule B number or a Harmonized Tariff System (HTS) code" [1]. No official table converts one to the other, because the two lists cut the same product on different axes.

Take a microcontroller. In the HTS, it goes to subheading 8542.31.00, "Processors and controllers," and the statistical suffix splits controllers by bit width: 8-bit, 16-bit, 32-bit, other [6]. The CCL does not care about bit width there. 3A991.a catches microcontroller microcircuits with a clock frequency above 25 MHz, a performance of 5 GFLOPS or more with a 32-bit or wider arithmetic logic unit, or certain multiple-bus designs [3]. So two 32-bit microcontrollers under the same 10-digit HTS number, one at 48 MHz and one at 20 MHz, can carry different export answers: 3A991 (paragraph a.2) for the first, unless an encryption function moves it to Category 5 Part 2, and EAR99 for the second if it meets no paragraph of 3A991.a and no other entry.

ECCNHTS codeSchedule B
ListCommerce Control List (15 CFR Part 774, Supp. No. 1)Harmonized Tariff Schedule of the United StatesSchedule B, Census Bureau
Who runs itBIS (Commerce)USITC publishes; CBP administers at entryCensus Bureau
What it decidesWhether an export needs a licenseU.S. import duty and statisticsU.S. export statistics
FormatFive characters, e.g. 3A991, plus a paragraph10 digits10 digits
Classified byTechnical parameters (speed, power, performance)What the article is, by the General Rules of InterpretationSame structure as the HTS at 6 digits
On the export filingECCN (when required) with the license authorityMay be reported in place of Schedule BCommodity classification field

The export filing needs both kinds of number. The Foreign Trade Regulations ask for the 10-digit Schedule B number in the EEI's commodity classification field, with the HTS number allowed in its place [8], and 15 CFR 758.1(g) asks for the ECCN "when required," the license authority (license number, license exception or NLR), and an item description in CCL terms [8]. Your broker's HTS work covers the first; the ECCN is a second classification. For the import and export tariff numbers side by side, see HTS code vs Schedule B.

What changed on the Commerce Control List in 2025 and 2026?

The chip controls that matter most to Category 3 classification were written in December 2024 and January 2025; the 2026 rules changed license requirements, license policy and deadlines rather than adding ECCNs. The dated changes behind today's Category 3 and 4 entries and their license policy:

DateRuleWhat it did
December 5, 202489 FR 96790Added ECCNs 3B993 and 3B994 for certain semiconductor manufacturing equipment, with destination controls [7]
January 15, 202590 FR 4544Added ECCN 4E091 for the weights of the most advanced AI models [10]
May 13, 2025BIS announcementBIS said it would rescind the AI Diffusion rule and not enforce it; 4E091 still appears in the eCFR text current to October 29, 2026 [11] [3]
January 15, 202691 FR 1684License review for Nvidia H200-class and less advanced chips to China and Macau moved from a presumption of denial to case-by-case, with certifications; the license requirement stayed (license review policy in Part 742; CCL text unchanged) [12]
April 9, 202691 FR 17851Moved the deadline to apply for approved integrated circuit designer status to December 31, 2026 [13]
July 14, 202691 FR 43034Moved the United Arab Emirates to Country Group A:5 and rewrote an RS license line in 3A001, 3A090, 3D001 and related Category 4 and 5 entries to name the UAE [14]

A classification is a reading of the CCL text on a date. Keep the eCFR "current as of" date with each ECCN in your records, so the next rule that touches Category 3 tells you which parts to reread.

Where does GingerControl's Export Control Classifier fit?

The steps above, read the entry, test the datasheet, record the paragraph and the date, are the part that eats time when the ERP's ECCN field is empty on thousands of parts. That is the work I built GingerControl's Export Control Classifier for: it reads your uploaded spec, datasheet or firmware documentation, extracts the controlled parameters, narrows the Commerce Control List (Categories 0 to 9) to one ECCN, or returns EAR99 when no entry applies, asks only the questions the documents leave open, and writes a research report your export counsel can check.

What it does not do matters as much. It works under the EAR and the CCL only: it does not cover ITAR or the USML, it does not decide license requirements or license exceptions, and it does not screen end users. It runs in the GingerLite web app, next to the Classification Researcher for the HTS code on the import side, as two separate classifications, and it has no API. For the wider tool landscape and how to self-classify a whole product master, see my comparison of ECCN classification software.

ApproachWhat you getWhere it falls short
GingerControl Export Control ClassifierOne ECCN or EAR99 per item, with a research report of the parameters testedEAR and CCL only; no license determination or screening
Manual reading of the eCFR textThe current text, datedHours per complex part; the record is as good as the analyst's notes
Manufacturer-supplied ECCNThe maker's own readingBIS has not checked it, and your assembly may classify differently
BIS commodity classification requestAn official answer with a CCATS number, within 14 calendar days of receipt by rule (15 CFR 750.2(a))One request per batch of up to six items; too slow for a whole catalog

Which route fits which part: if the maker of a standard part publishes its ECCN with the paragraph, check that paragraph against the current text and keep it; if you designed the part, or integrated it into an assembly, classify it yourself from the datasheet; if your own reading leaves two entries open on a high-risk part, ask BIS. For semiconductor equipment headed to China, my note on 3B991 license processing covers the licensing side.

Bottom line: For an export compliance lead at an electronics manufacturer with 20,000 parts and an empty ECCN field, the CCL entry and the datasheet decide every answer, and the HTS code decides none. Read Category 3's software and technology groups as well as 3A, record the eCFR date with each ECCN, and keep BIS requests for the parts your own reading cannot settle.

Where this fits in your export compliance workflow

When the problem is one part at a time, the Export Control Classifier gives you the ECCN or EAR99 with a report your counsel can check, in the same GingerLite app as the Classification Researcher. When it is 20,000 parts, plants in three countries and a CCL that keeps moving, GingerOS, GingerControl's AI trade compliance platform, rechecks export control, FTA eligibility and origin documents whenever a rule or a record changes, and writes approved results back to your ERP with an audit trail. It starts with Prototype Week: one call, then a clickable prototype of your own flow in three days. See GingerOS recheck export control on your own parts

References

  1. Bureau of Industry and Security, "Classify your item"
    Data cited: ECCN definition ("five character alpha-numeric designations"); self-classification, manufacturer and BIS routes; ECCN "distinct from and entirely unrelated to" Schedule B and HTS
    Source: BIS, Classify your item
    Read: November 2, 2026
  2. eCFR, 15 CFR 738.2, Commerce Control List (CCL) structure
    Data cited: The 10 categories, the five product groups, Table 1 to paragraph (d)(1) (reasons for control by the last three digits), the four sections of an entry and how to read the heading
    Source: eCFR, 15 CFR 738.2
    Current as of: October 29, 2026
  3. eCFR, Supplement No. 1 to Part 774, The Commerce Control List
    Data cited: GingerControl's count of 78 Category 3 ECCN headings by product group and reason for control; the text of 3A001 and 3A991; the headings of 3A002, 3A090, 3A992, 3B001, 3B993, 3B994, 3D991 and 3E991; 4E091 in the current text; EAR99
    Source: eCFR, Supplement No. 1 to Part 774
    Current as of: October 29, 2026
  4. eCFR, Supplement No. 4 to Part 774, Commerce Control List Order of Review
    Data cited: USML check first; 600 series and 9x515 entries "trump other ECCNs"; EAR99 only when no ECCN in any category describes the item; end use, end user and destination license requirements for EAR99 items
    Source: eCFR, Supplement No. 4 to Part 774
    Current as of: October 29, 2026
  5. eCFR, Supplement No. 1 to Part 738, Commerce Country Chart
    Data cited: China, Germany and India rows for NS 1, NS 2, RS 2 and AT 1
    Source: eCFR, Supplement No. 1 to Part 738
    Current as of: October 29, 2026
  6. U.S. International Trade Commission, Harmonized Tariff Schedule, subheading 8542.31.00
    Data cited: "Processors and controllers"; statistical suffixes for 8-bit, 16-bit and 32-bit controllers
    Source: USITC, HTS search for 8542.31
    Read: November 2, 2026
  7. Federal Register, "Foreign-Produced Direct Product Rule Additions, and Refinements to Controls for Advanced Computing and Semiconductor Manufacturing Items," 89 FR 96790
    Data cited: New ECCNs 3B993 and 3B994 for semiconductor manufacturing equipment
    Source: Federal Register, 2024-28270
    Published: December 5, 2024
  8. eCFR, 15 CFR 30.6 and 15 CFR 758.1, Electronic Export Information
    Data cited: Schedule B or HTS number in the commodity classification field (30.6(a)(12)); ECCN when required, license authority and CCL-terms description on the EEI (758.1(g))
    Source: eCFR, 15 CFR 758.1 and eCFR, 15 CFR 30.6
    Current as of: October 29, 2026
  9. Federal Register, "One Year Suspension of Expansion of End-User Controls for Affiliates of Certain Listed Entities," 90 FR 50857
    Data cited: Stay of the affiliates rule (90 FR 47201) until November 9, 2026, absent a future extension
    Source: Federal Register, 2025-19846
    Published: November 12, 2025
  10. Federal Register, "Framework for Artificial Intelligence Diffusion," 90 FR 4544
    Data cited: ECCN 4E091 for AI model weights
    Source: Federal Register, 2025-00636
    Published: January 15, 2025
  11. Bureau of Industry and Security, rescission of the AI Diffusion rule
    Data cited: May 13, 2025 announcement that BIS would rescind the rule and not enforce it
    Source: BIS press release
    Published: May 13, 2025
  12. Federal Register, "Revision to License Review Policy for Advanced Computing Commodities," 91 FR 1684
    Data cited: Case-by-case review for H200-class and less advanced chips to China and Macau, with certifications; license requirement unchanged
    Source: Federal Register, 2026-00789
    Published: January 15, 2026
  13. Federal Register, "Extension of Authorized Integrated Circuit (IC) Designer Status and Application Deadline To Become an Approved IC Designer," 91 FR 17851
    Data cited: New date of December 31, 2026
    Source: Federal Register, 2026-06851
    Published: April 9, 2026
  14. Federal Register, "Enhanced Favorable Treatment for the United Arab Emirates Under the Export Administration Regulations," 91 FR 43034
    Data cited: UAE moved to Country Group A:5; One RS License Requirements line in 3A001, 3A090, 3D001 and related Category 4 and 5 ECCNs revised to name the UAE
    Source: Federal Register, 2026-14132
    Published: July 14, 2026
  15. eCFR, 15 CFR 744.21 and Supplement No. 2 to Part 744, military end use and end user controls
    Data cited: License requirement for 3A991 items for a military end use or military end user in China, among other destinations
    Source: eCFR, 15 CFR 744.21
    Current as of: October 29, 2026

Questions people ask

For an exporter whose broker already supplied HTS codes, what is the difference between an ECCN and an HTS code?

An ECCN is a five-character code from the Commerce Control List that decides whether an export needs a license; an HTS code is a 10-digit number from the Harmonized Tariff Schedule that sets U.S. import duty and statistics. BIS calls the ECCN distinct from and entirely unrelated to Schedule B and HTS numbers. For an exporter with broker-supplied HTS codes on 20,000 parts, every ECCN still has to be classified separately.

Is an ECCN the same as a harmonized code, and can you convert an HTS code to an ECCN?

No, and no table converts one to the other. The two lists cut the same product on different axes: HTS subheading 8542.31.00 splits controllers by bit width, while ECCN 3A991.a splits microcontrollers by clock speed and processing performance. For a manufacturer with thousands of 32-bit microcontrollers under one HTS number, each part's ECCN comes from its own datasheet.

Which goes on the EEI filing for an export shipment: the ECCN, the Schedule B number or the HTS code?

Both kinds of number. The Foreign Trade Regulations ask for a 10-digit Schedule B number, or the HTS number in its place, in the commodity classification field, and 15 CFR 758.1(g) asks for the ECCN when required, with the license authority and a description in CCL terms. If your forwarder files EEI for 40 shipments a month, the two numbers on each line come from two separate classifications.

For an exporter documenting ECCNs, what is the BIS Commerce Control List, and where is the official text?

The Commerce Control List is Supplement No. 1 to Part 774 of the Export Administration Regulations, the list of items BIS controls by ECCN. The continuously updated text is on the eCFR, an authoritative but unofficial edition where each version is dated; BIS's Interactive Commerce Control List is a search tool built on that text. If you are documenting ECCNs for 20,000 parts, cite the eCFR text and the date it was current with each one.

For an electronics manufacturer new to export controls, how is the Commerce Control List organized into categories and product groups?

Into 10 categories, 0 Nuclear through 9 Aerospace and Propulsion, each split into the same five product groups: A equipment, assemblies and components; B test, inspection and production equipment; C materials; D software; E technology. If you make electronic components, Category 3 holds most of your work, and 34 of its 78 entries are software and technology, in 3D and 3E rather than next to the hardware in 3A.

What does CCL Category 3 cover for an electronic components manufacturer?

Category 3 is Electronics: components such as integrated circuits, microwave transistors and power devices, general purpose electronic equipment, semiconductor manufacturing and test equipment, wafer materials, and the related software and technology. By GingerControl's count of the eCFR text current to October 29, 2026, it has 78 ECCN headings. If you ship chips, modules and test equipment, 34 of those headings cover the software and technology you may also export.

For an integrated circuit, how do 3A001, 3A991 and EAR99 differ?

3A001 controls electronic items that meet its higher thresholds, mainly for national security; 3A991 is the anti-terrorism-only entry for devices and components not controlled by 3A001, such as microcontrollers with a clock above 25 MHz; EAR99 means no ECCN describes the part. For an exporter shipping one chip family to China, Germany and India, the entry decides which destinations need a license.

How do you read a CCL entry's reasons for control against the Country Chart for a shipment to China?

Take each line of the entry's License Requirements, such as NS Column 2, and find that column on the Country Chart in Supplement No. 1 to Part 738. An X in the destination's row means a license is required unless a license exception applies. On the chart current to October 29, 2026, China has an X under NS 2; Germany and India do not, so one 3A001 part can need a license for one of your three distributors and not the other two.

When classifying a part against the CCL, what is the order of review, and why are 600 series entries checked first?

The order of review in Supplement No. 4 to Part 774 sets the steps for classifying an item: confirm it is not on the USML, find the category and product group, check the 600 series and 9x515 entries first, then every other ECCN in the group, and only then call it EAR99. The 600 series and 9x515 entries come first because they trump other ECCNs that also describe the item, which matters if any of your 20,000 parts were specially designed for a military item or spacecraft, or are radiation-hardened.

For a manufacturer with an empty ECCN field, do all products have an ECCN, or can an exported part have none?

Every item subject to the EAR either has an ECCN or is EAR99, the designation for items no ECCN describes. Some items are not subject to the EAR at all, such as items under another agency's exclusive control. If you are filling an empty ECCN field across 20,000 parts, EAR99 is the result of a review, recorded like any other classification, not a default for unchecked parts.

When BIS changes the Commerce Control List, do ECCNs already in the ERP need a recheck?

Yes, for every part in a category the rule touches. A classification is a reading of the CCL text on a date, and BIS amends that text by Federal Register rule, such as its July 2026 rule that amended the license requirements of 3A001 and 3A090. If your ERP holds ECCNs on 20,000 part records, keep the eCFR date with each classification, so a new rule shows you which parts to reread.

Your next step

Classifying SKUs one ruling at a time?

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Try the Classification Researcher on one product Get your SKU list classified, reasons included

Pick a 30-minute slot on the next page with Chen Cui, our CEO. Bring one notice or one SKU list (an ERP export, a spreadsheet or an email will do) and see what GingerOS does with it.

Reviewed by Michael Weick, LCB / CCS
Customs compliance manager with 42 years of experience (ex Subaru of America, Merck, and Motorola).

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