The ABCs of the CCL: Spotlight on Parts and Components

Unsure about the intricacies of commodity classification? Well, you’re in luck since our expert, Bruce Webb, is preparing a series of blogs to demystify the Commerce Control List. This is the second of our series and focuses on “Parts and Components.”  Take it away Bruce.

Hello again everyone.  When classifying items under the Export Administration Regulations (EAR), the phrase “Parts and Components” consistently appears in the various Export Control Classification Number (ECCN) entries on the Commerce Control List (CCL). Although they appear to identify the same things, these two terms have very specific and separate meanings defined in Part 772.1 of the EAR.

The scope of each ECCN entry is affected by the presence or absence of these terms. When the terms “Parts and Components” appear in an ECCN, the entry will control those items within its scope, whether they are general purpose parts or specially designed for the item. If those terms do not appear, only the specified item is controlled and not its parts or components.

In general terms, a “part” is defined as a single element of a component, accessory or attachment that is not normally subject to further disassembly without destroying it or rendering it nonfunctional. A part is considered the lowest level of disassembly of a manufactured item and does not have any moving elements beyond bending or twisting. Both the EAR and the International Traffic in Arms Regulations (ITAR) identify the following ‘parts’ as uncontrolled:  screws, bolts, nuts, nut plates, studs, inserts, other fasteners (e.g., clips, rivets, pins), common hardware (e.g., washers, spacers, insulators, grommets, bushings), springs and wire.

In contrast, a “component” is more broadly defined in terms of an end item. The EAR refers to a “component” or an “assembly” as being the same but further breaks them down into major or minor components. A “major component” is an assembled element of an end item. It’s the type of component where the end item would be inoperable without the use of the major component. However, a “minor component” is any assembly element of a “major component” or an accessory or attachment without which the end item is still operable. Within the CCL, the term “components” refers to both major and minor components.

The process of identifying whether a part or component is “Specially Designed” is much more complex and will be addressed in our next post.