Registration under the Export Administration Regulations is done electronically through the Bureau of Industry and Security’s Simplified Network Application Process Redesign, known as SNAP-R. The process is free, produces a Company Identification Number (CIN), and is the prerequisite for filing export license applications, commodity classification requests, and other submissions with BIS. Getting the details right matters, because mistakes on the form can slow you down when you have an export waiting.
Do You Actually Need to Register
Not every U.S. exporter needs a SNAP-R account. You need one when you deal in items that require an export license, when you want BIS to classify an item for you, or when you want to use certain license exceptions that require filing. Working out which of those apply to you starts with classifying your product.
The EAR, codified at 15 CFR Parts 730–774, covers the export, re-export, and in-country transfer of “dual-use” items: goods, software, and technology that have both commercial and military applications. BIS organizes controlled items on the Commerce Control List (CCL) by Export Control Classification Number (ECCN), a five-character code that identifies the item and the reasons it is controlled. If your item is subject to the EAR but doesn’t match any ECCN, it is designated EAR99. Most EAR99 items can be exported without a license, though a license is still required if the destination, end user, or end use is restricted.
Registration is also relevant if you employ foreign nationals with access to controlled technology. Under 15 CFR 734.13, releasing controlled technology or source code to a foreign person inside the United States is a “deemed export” to that person’s most recent country of citizenship or permanent residency, and it may require a license before the release happens. Lawful permanent residents and “protected individuals” under the Immigration and Naturalization Act are not covered by the deemed export rules. For anyone else, the license application must include current copies of the foreign person’s passport, visa, and work authorization, and only one foreign person may be listed per application.
EAR or ITAR
Before registering with BIS, confirm you are in the right system. The International Traffic in Arms Regulations (ITAR), administered by the State Department’s Directorate of Defense Trade Controls, covers items on the United States Munitions List and uses its own DECCS portal. If your products are designed specifically for military use, ITAR likely applies and you register there instead. Dual-use and purely commercial items sit under the EAR and BIS.
What to Gather Before You Open the Form
Having the right information in hand before you start saves time and prevents rejections. BIS asks for:
- The exact legal entity name as it appears on official government filings. This is the “Principal Party in Interest.”
- A physical street address where the business operates. P.O. boxes are not accepted. Provide a separate mailing address if it differs.
- An Employer Identification Number (EIN), if you plan to submit export license applications (specifically, if you will mark “Export” in Block 5 of the license application). Individuals filing on their own behalf and agents filing on behalf of an exporter may be exempt.
- A direct phone number and professional email address for the person submitting the registration. Avoid generic group inboxes, because this person becomes the account administrator.
- A brief description of your business activities and the types of items you intend to export or classify.
Double-check the EIN and address against your other federal filings. Discrepancies between SNAP-R and other government records are one of the more common reasons BIS comes back with follow-up questions.
Screening Obligations You’ll Inherit
Registration itself doesn’t screen anyone, but once you have a CIN and start filing, you are expected to check every party to every transaction against the Consolidated Screening List, which combines restriction lists maintained by Commerce, State, and Treasury. The Entity List (Supplement No. 4 to Part 744) is particularly consequential: a license is required for exporting any item subject to the EAR when a listed entity is a party, and those requirements apply on top of any others in the EAR. The restrictions extend to foreign entities that are 50 percent or more owned by one or more listed entities.
Non-U.S. Companies
Foreign companies can register in SNAP-R. The form accepts international addresses, and an EIN isn’t required for every type of filing. There is a real limit, though: submitting an export license application (as opposed to a re-export authorization, classification request, or notification) requires the applicant company to be located in the United States. A foreign company that needs to apply for re-export authorization can register and use the system for that.
Submitting the Registration
Registration happens entirely online through the SNAP-R portal at snapr.bis.gov. The form walks you through company information, contact details, and identification numbers, and ends at a review screen showing everything you entered. Read this screen carefully. When you submit, the system runs an automated check to confirm no required fields are blank and returns a confirmation screen with a submission identifier. Save it.
Verification and Activation
BIS then verifies your submission against federal records, including your EIN and company address. If something doesn’t match, the agency may contact the administrator for additional documentation. BIS does not publish a specific processing timeline for SNAP-R registrations, so build in lead time rather than waiting until you have an export in motion. Once approved, you receive your CIN and an email with an activation link. Follow the link, and the full SNAP-R toolset opens up: license applications, commodity classification requests, and license exception notifications.
The Administrator Role
Whoever submits the registration becomes the initial account administrator, and that role carries real authority. The administrator can submit applications on the company’s behalf, add and remove users, grant administrative rights to others, and manage third-party relationships. Every user within a CIN must have a unique email address.
The administrator also controls access to work in progress. Through SNAP-R’s self-management section, an administrator can add users, promote other users to administrator, disable accounts for departed employees, re-enable previously disabled accounts, and reassign pending applications or classification requests from one user to another within the same CIN. That last function matters when someone goes on leave or changes roles.
BIS expects active account hygiene. Deactivate a user account immediately when the person leaves the company or is no longer authorized to submit on the company’s behalf. Leaving dormant accounts open for former employees is a compliance risk, not a housekeeping oversight.
What Registration Doesn’t Handle
Getting a CIN is the administrative starting line. Two obligations come with it that are worth understanding before you start filing.
Five-Year Recordkeeping
Once you export, 15 CFR Part 762 requires you to keep records for five years from whichever is latest: the date of the export, any known re-export or transfer, or any other termination of the transaction. The scope is broader than license paperwork. BIS requires you to retain correspondence, contracts, memoranda, notes, financial records, invitations to bid, and any notifications from BIS about applications that were returned, denied, or classified. Documents you submitted electronically through SNAP-R don’t need to be separately retained, but everything else tied to the transaction must be. Firearms exporters controlled under specific ECCNs have an added requirement to retain the serial number, make, model, and caliber of each firearm exported, and this applies to any party that creates or receives such records.
Penalty Exposure
Willful violations of the EAR carry criminal penalties of up to $1,000,000 per violation and up to 20 years of imprisonment for individuals, or both, and reach anyone who willfully commits, attempts, conspires, or aids in an unlawful export. Civil penalties can reach $374,474 per violation or twice the value of the transaction, whichever is greater; that dollar figure is the 2025 inflation adjustment. BIS can also deny export privileges outright through a denial order published in the Federal Register, which cuts the sanctioned party off from any transaction subject to the EAR.
Voluntary Self-Disclosure (VSD) is BIS’s mitigation route. For serious violations, filing a VSD caps the base penalty at half the statutory maximum. Choosing not to disclose a significant violation that BIS later discovers is treated as an aggravating factor and eliminates mitigation credit.
After the CIN
Registration puts you in the system. It doesn’t classify your products, screen your customers, train your staff, or keep your records. BIS expects a registered exporter to run an actual compliance program covering classification, screening, recordkeeping, training, and internal audit. The companies that end up in enforcement actions are rarely the ones that never registered. They are the ones that registered, started exporting, and never built the infrastructure behind the account.