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Commodity Classification Automated Tracking System
(CCATS)
What is the Commodity Classification Automated Tracking System (CCATS)?
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The Commodity Classification Automated Tracking System (CCATS) is a process whereby the U.S. Department of Commerce classifies hardware, software, and technology subject to the Export Administration Regulations (EAR) for industry. If a customer or business partner asks, “if you have a CCATS,” they are asking if the US Department of Commerce (DoC) has confirmed your item’s licensing classification in a written determination.
Managed by the DoC Bureau of Industry and Security (BIS), the CCATS process assigns the correct Export Control Classification Number (ECCN) to items based on their technical characteristics and end-uses. CCATS primarily apply to dual-use items, technologies, and software – meaning they can have both commercial and military applications. ECCN classification is essential for verifying with the US government whether an export requires a license for export to a particular country. CCATS are useful tools to help ensure and document compliance with export control regulations, especially for goods with potential national security or foreign policy implications. Businesses submit a written classification request to BIS and in turn receive an official ECCN determination with a CCATS number. CCATS also offer the ability to request reclassification or appeal BIS decisions, providing options for possible resolution if BIS makes an unfavorable determination.​
How do CCATS impact businesses?​
CCATS play a crucial role in helping businesses ensure compliance with U.S. export regulations by providing accurate ECCN classifications. Proper classification is fundamental in determining whether an export requires a license, and in some cases, such as in cryptography, it is required to use a license exception. Businesses involved in international trade may self-classify using the item’s characteristics and reviewing the EAR’s Commerce Control List (CCL). However, in some instances, especially those involving sensitive technologies, the classification may be difficult to determine or may fall into multiple categories. A CCATS eliminates the risk of misclassification and documents BIS’s classification determination to help exporters avoid penalties, fines, or criminal liability. Accurate classification under CCATS is vital for businesses seeking to enter or expand in foreign markets, comply with licensing requirements, and mitigate risks related to national security or foreign policy concerns.
How can Schulz Trade Law PLLC (STL) help clients with CCATS?
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Schulz Trade Law PLLC (STL) provides guidance to businesses choosing the CCATS process to classify products before exporting. Our attorneys and trade advisors regularly draft CCATS submissions, assist in self-determining the correct ECCN, clarify licensing requirements, and help ensure compliance with U.S. export control laws. STL’s services include assisting businesses through the CCATS classification process, addressing classification challenges, and leading the submission of reclassification or appeal requests when necessary. By leveraging STL’s knowledge and experience, businesses can maintain up-to-date compliance with export regulations, navigate complex licensing issues, and optimize their international trade strategies with the support of reliable documentation.