The Commerce Country Chart is the grid in Supplement No. 1 to Part 738 of the Export Administration Regulations that tells you, for a given item and destination, whether the U.S. government requires a license before you can ship.1eCFR. Supplement No. 1 to Part 738 – Commerce Country Chart Countries run down the left; reasons an item can be controlled run across the top. Where your item’s control reasons and your destination country intersect, an “X” means you need a license. No “X” means the chart itself does not require one, though other rules still might.
Using the chart is a three-step exercise. You classify the item, read the grid, and then check the prohibitions that operate independently of what the grid shows.
What You Need Before You Open the Chart
The chart is useless without two pieces of information about your product: its Export Control Classification Number (ECCN) and the reasons it is controlled. Both come from the Commerce Control List in Supplement No. 1 to Part 774.2eCFR. Supplement No. 1 to Part 774 – The Commerce Control List
An ECCN is a five-character alphanumeric code, like 3A001 or 5D002. You find yours by comparing your product’s technical specifications against the descriptions on the list. Each ECCN entry names the reasons the item is controlled, shown as two-letter abbreviations: NS for National Security, NP for Nuclear Nonproliferation, MT for Missile Technology, AT for Anti-Terrorism, and others. Some reasons also carry a column number, such as NS Column 1 or NS Column 2, and that column number is what you will use on the chart.
If nothing on the Commerce Control List describes your product, it falls into the catch-all designation EAR99. Most commercial goods land there. EAR99 items can generally ship without a license, but the country chart analysis is not the last word: an EAR99 item still needs a license if it is going to an embargoed country, a prohibited end-user, or a prohibited end-use.
When your item’s technical parameters make classification ambiguous, you can ask the Bureau of Industry and Security (BIS) for an official determination through a commodity classification request in the SNAP-R system.3Bureau of Industry and Security. Licensing That gives you a defensible record if the classification is later questioned.
Reading the Chart
With the ECCN and its control reasons in hand, the mechanics are straightforward. Find your destination country in the left-hand column. Then move across the row and look at each column that matches a reason for control listed in your ECCN entry, including the correct column number where the ECCN specifies one.
If an “X” appears at any intersection between your country’s row and an applicable control column, you have a license requirement. A single “X” under a single applicable column is enough. You cannot ship without either a license or a qualifying license exception.
If no “X” appears in any of the intersecting boxes, the item may qualify for “No License Required” (NLR) treatment. Read the chart’s footnotes before you decide, because they reference special provisions that override what the boxes alone appear to say.
What NLR Actually Requires
NLR is not a clearance. It means the chart-based analysis did not trigger a license. To actually ship under NLR, three additional conditions must all hold.4eCFR. 15 CFR 738.4 – Determining Whether a License Is Required
- General Prohibitions Four through Ten do not apply. These cover denial orders, prohibited end-uses and end-users, embargoed destinations, and related conduct.
- The ECCN entry does not impose additional license requirements that the chart does not capture.
- Any applicable encryption requirements under Part 740.17(b) are met.
Even after confirming NLR, you still owe the export clearance procedures in Part 758 and the recordkeeping obligations in Part 762. No license does not mean no paperwork.
What the Chart Does Not Show
A clean read on the Country Chart is the beginning of the compliance analysis, not the end. Several federal prohibitions operate independently of the grid.
Embargoed and Sanctioned Destinations
Part 746 of the EAR imposes controls on embargoed and sanctioned countries that go far beyond anything the chart’s X marks convey.5eCFR. 15 CFR Part 746 – Embargoes and Other Special Controls Country Group E:1 (state sponsors of terrorism) and E:2 (unilateral embargo) face the broadest restrictions. As of 2026, those groups include Cuba, Iran, North Korea, and Syria.6eCFR. Supplement No. 1 to Part 740 – Country Groups Virtually all items subject to the EAR require a license for these destinations, including many EAR99 goods, and applications face a general policy of denial.
Russia and Belarus carry separate extensive sanctions under Section 746.8. Country Group D:5 lists countries subject to U.S. arms embargoes, including China, Russia, and Venezuela, with additional requirements for certain categories such as firearms.
End-Users, End-Uses, and Restricted Parties
General Prohibition Five bars exports to prohibited end-uses or end-users regardless of what the chart shows. It is the prohibition that catches an EAR99 transaction supporting weapons of mass destruction, military-intelligence end-users, or other activities flagged in Part 744.7eCFR. 15 CFR 736.2 – General Prohibitions and Determination of Applicability
Every transaction should be screened against the Consolidated Screening List, which the International Trade Administration maintains by combining the restricted-party lists from Commerce, State, and Treasury.8International Trade Administration. Consolidated Screening List The key components:
- Entity List, whose parties trigger license requirements beyond the chart.
- Denied Persons List, of parties whose export privileges have been revoked.
- Unverified List, of end-users BIS could not verify in prior transactions.
- Military End User List, which triggers license requirements for a broad range of items to listed foreign military end-users.
- Specially Designated Nationals List, maintained by OFAC.
BIS also publishes “red flag” indicators in Supplement No. 3 to Part 732: a buyer reluctant to describe the end-use, a product whose capabilities do not fit the buyer’s business, a customer who declines routine installation or training, or an unusual shipping route.9eCFR. Supplement No. 3 to Part 732 – BIS Know Your Customer Guidance and Red Flags Ignoring a red flag you know about can establish the “knowledge” element that turns a civil case into a criminal one.
License Exceptions
An “X” on the chart does not always mean a full license application. Part 740 authorizes license exceptions that permit certain exports without individual approval when the transaction meets stated conditions.10eCFR. 15 CFR Part 740 – License Exceptions The ECCN entry lists which exceptions are potentially available for that item, using three-letter codes.
Two are common enough to know by name. LVS (Limited Value Shipments) allows export of eligible commodities when the net value of controlled items in the shipment falls below the dollar limit stated in the ECCN entry; the threshold varies by classification. GBS (Shipments to Country Group B) allows exports to Country Group B destinations when the only reason for control is national security and the ECCN entry indicates “GBS—Yes.”
Every exception has its own eligibility rules, country restrictions, and documentation requirements. Relying on one without confirming each condition carries the same enforcement risk as shipping with no authorization at all, and no exception overrides the end-use or end-user prohibitions.
Deemed Exports: The Chart Applied Inside the United States
Releasing controlled technology or source code to a foreign person inside the United States counts as a “deemed export” to that person’s country of citizenship or permanent residency.11eCFR. 15 CFR 734.13 – Export The same chart analysis applies: you check the technology’s reasons for control against the individual’s country of nationality, and if an “X” appears, you need a license before making the release. U.S. citizens, lawful permanent residents, and individuals granted protected status are exempt.12Bureau of Industry and Security. What Is a Deemed Export?
Companies with multinational workforces often discover deemed export obligations only during an audit. The chart is the same tool; the trigger is different.
If the Chart Says You Need a License
When the chart shows a requirement, no exception applies, and no flat prohibition blocks the transaction, you file a license application through SNAP-R, the BIS electronic portal.3Bureau of Industry and Security. Licensing Your company first needs a Company Identification Number, obtained by registering on the SNAP-R site.13Bureau of Industry and Security. SNAP-R – Simplified Network Application Process Redesign The application uses form BIS-748P and collects classification, technical specifications, foreign recipient information, and end-use details.14eCFR. Supplement No. 1 to Part 748 – BIS-748P Multipurpose Application Instructions There is no filing fee. An approved license may include conditions you are legally bound to follow.
Getting It Wrong
Under the Export Control Reform Act of 2018, criminal violations carry up to 20 years in prison and fines of up to $1 million per violation.15Bureau of Industry and Security. Penalties Civil penalties reach up to $374,474 per violation as of 2026, adjusted annually for inflation.16eCFR. 15 CFR Part 6 – Civil Monetary Penalty Adjustments for Inflation BIS can also deny a company’s export privileges outright.
Every export transaction generates records you must keep for five years, measured from the latest of the export, any known reexport or diversion, or the transaction’s termination.17eCFR. 15 CFR 762.6 – Period of Retention That obligation applies to NLR shipments too. The records include license applications, shipping documents, end-user certifications, buyer correspondence, internal classification analyses, and any documentation supporting a license exception. If any agency requests a specific record, you cannot destroy it without written authorization, even after the five-year period expires.