There are multiple ways the EAR organizes and identifies countries for exporters. Keeping them straight can be a challenge. Here’s an overview of each listing of nations and the purpose it serves.

Commerce Country Chart

For items subject to the EAR, there are three main variables to determine whether NLR applies:

  1. The item classification;
  2. Any reasons for control;
  3. The destination country to which an item is bound.

If an item has an Export Control Classification Number (ECCN), then the applicable reasons for export control are provided beneath the ECCN heading on the Commerce Control List (CCL), per the image capture below. (See related post: NLR Authorization and Exporting Without a License.)

There are several reasons for control, including:

  • CB: Chemical and biological weapons
  • NP: Nuclear nonproliferation
  • NS: National security
  • MT: Missile technology
  • RS: Regional stability
  • FC: Firearms convention
  • CC: Crime control
  • AT: Anti-terrorism

This information connects with the third variable – destination country – through the Commerce Country Chart.

If there is an “X” in the box where a country intersects with the reason for control, it means an export license is required. If the boxes for all the applicable reasons for control are empty for a given destination, the item is eligible for NLR to that destination. (Even if a transaction appears to qualify for NLR, it is essential before proceeding to ensure that no end-use or end-user-based license requirements apply.)

The Commerce Country Chart is applied early in any EAR license determination and is one of the more definitive and straightforward aspects of the regulations. Even so, the chart does not address all the EAR’s reasons for control. United Nations (UN) and Encryption Items (EI) controls, among others, are explained elsewhere in the regulations.

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Country Groups

  • Supplement No. 1 to Part 740 of the EAR
  • Primary use: To determine whether a license exception may (or may not) apply.
  • Secondary use: To identify countries of particular concern for certain reasons, sometimes triggering additional Part 744 license requirements based on end-use.

If an item isn’t eligible for export as NLR, it may still be eligible for a license exception, which usually means referring to the Country Groups.

This list organizes every country into four groups.

Group A countries are those with which the United States has multilateral agreements or control regimes (such as the 1996 Wassenaar Arrangement) that govern broad categories of exports. Originally it was subdivided into subgroups for each of these agreements.

As geopolitical relationships have evolved over time, exceptions have been introduced – mostly involving military and space-related items – and the subgroups have been extended to address these changes.

Countries in Group A garner some of the most favorable treatment available in the EAR. Countries in subgroups A:5 and A:6 are eligible destinations under License Exception STA (Section 740.20 of the EAR; Strategic Trade Authorization).

Governments of subgroup A:1 countries (plus Singapore and Taiwan) are considered “cooperating governments,” qualifying for License Exception GOV (Section 740.11; Governments).

Group B, which is the only group that isn’t subdivided, encompasses most countries in the world and represents destinations where license exceptions are uniformly available. You can think of it as a list of countries with which the U.S. has a basic level of trust with respect to trade.

Most major U.S. trading partners are represented in Group B, though both China and Vietnam – which are the United States’ 3rd– and 10th-ranked trading partners, respectively – are not.

Group C: Undefined and held in reserve for future use.

Group D countries face more restrictions and are generally allowed fewer license exceptions. There are roughly 50 Group D countries, including many of the former Soviet republics, Middle Eastern nations and others around the world with unstable governments. Group D is organized in five subgroups based on a list of concerns that is different (but similar) to those in the Commerce County Chart:

  • D:1: National Security
  • D:2: Nuclear
  • D:3: Chemical & Biological
  • D:4: Missile Technology
  • D:5: U.S. Arms Embargoed Countries (some in line with UN sanctions, others by unilateral U.S. policy)

Group D:5 is drawn from the International Traffic in Arms Regulations (ITAR). If a country is under embargo in the ITAR, that embargo applies immediately to the EAR as well, even if the EAR has yet to be amended to reflect the embargo.

Group E represents states under general embargo. Currently, it comprises only four countries—all of which also appear in Group D:

  • E1: Iran, North Korea and Syria, as state sponsors of terrorism;
  • E2: Cuba, which remains under unilateral U.S. embargo.

The Country Groups do change occasionally in an effort to keep up with world events. For example, over the past few years, Cambodia, Burma (Myanmar) and Russia have been added to Group D:5; Ukraine was removed from D:1 and added to B; and Sudan was removed from E:1 and added to B.

Referring to the Country Groups list can be tricky, because the wording for license exceptions differs across the EAR; in some instances, the regulation says a country must be in a specified country group to qualify for a license exception, and in other cases it will say country groups are excluded from license exceptions.

Also, in contrast to the Commerce Country Chart, an “X” in the appropriate box in Country Groups A or D simply indicates a country’s presence in that subgroup, while an empty box indicates the opposite.

Computer Country Tiers:

The list of Computer Tier 1 and Tier 3 countries determines where certain hardware, software and technology add-ons that enhance performance of high-end computers may be exported under Exception APP.

Only a small number of exporters will find their way to this corner of the EAR, which is concerned with issues of national security, nuclear proliferation and missile technology.

Contact the Export Compliance Training Institute

Do you have any questions about identifying the differences between the country lists in the EAR? Visit to learn about our company, our faculty, our staff and our esteemed Export Compliance Professional (ECoP®) certification program. To find upcoming e-seminarslive seminars and live webinars and browse our catalog of 80-plus on-demand webinarsvisit our ECTI Academy. You can also call the Export Compliance Training Institute at 540-433-3977 for more information.

Scott Gearity is President of ECTI, Inc.

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