Most goods can be imported into or exported from the United States without a specific license, but certain categories of products require permits, licenses, or certifications from federal agencies. The U.S.
19 steps across 4 sections
1. U.S. Customs and Border Protection (CBP)
- CBP oversees all goods entering the United States
- Every importer needs an importer number — either your IRS business registration number (EIN), Social Security number, or a CBP-assigned number
- CBP enforces import restrictions on behalf of other federal agencies (FDA, USDA, EPA, CPSC, etc.)
- Many small businesses hire a customs broker — a licensed professional who handles import documentation, classification, and compliance
2. Bureau of Industry and Security (BIS) / Export Administration Regulations (EAR)
- BIS administers the EAR, which controls exports of dual-use items (commercial goods that could have military applications)
- Items are classified using an Export Control Classification Number (ECCN) — a 5-character alphanumeric code
- First digit = category (e.g., electronics, materials, sensors)
- Second character (letter) = subcategory (e.g., equipment, test/inspection, technology)
- Last 3 digits = specific item
- EAR99 designation covers low-technology consumer goods that generally do not require an export license
- Exporters must check the Consolidated Screening List (CSL) to ensure they are not shipping to sanctioned parties
- Electronic Export Information (EEI) must be filed via the Automated Export System (AES) for shipments over $2,500 per classification, all used vehicle exports, and all licensed exports regardless of value
3. International Traffic in Arms Regulations (ITAR)
- Administered by the State Department's Directorate of Defense Trade Controls (DDTC)
- Covers defense articles, services, and related technical data on the U.S. Munitions List (USML)
- If there is doubt about whether an item falls under ITAR or EAR, exporters can submit a Commodity Jurisdiction (CJ) request to DDTC
- ITAR compliance requires registration with DDTC and strict record-keeping
4. Importer of Record
- The importer of record is the entity legally responsible for ensuring imported goods comply with all U.S. laws and regulations
- Responsible for accurate tariff classification, valuation, and payment of duties
- Can be the owner, purchaser, or a licensed customs broker acting on behalf of the owner
Common Mistakes
- Failing to screen buyers/end-users against the Consolidated Screening List
- Incorrect tariff or ECCN classification leading to wrong duty rates or unlice...
- Not filing EEI when required
- Assuming "EAR99" means no restrictions apply (sanctions and embargoes still a...
- Ignoring record-keeping requirements (5-year retention for exports)