An Export Control List Item Number (the “ECL Item
Number”) is the Canadian identification or classification
number that must be provided on export permit applications made
under the Export and Import Permits Act and, if
the good is subject to economic sanctions, requests for ministerial
authorizations. All goods that are subject to Canada’s export
controls regime have an ECL Item Number. Exporters of
controlled goods must determine the ECL Item Number.
Exporters of goods must determine if the good to be exported is
controlled by determining if there is an ECL Item Number for the
good. Goods that are not controlled (e.g., bananas), do not
have an ECL Item Number.
Every item that is on the Export Control List is known as an
“Item” and each “Item” is numbered.
The export controls classification exercise requires that you
review the “A Guide to Canada’s Export
Controls” – the Export Control List Item Numbers
are contained in that Guide.
Group 7: Chemical and Biological Weapons Non-Proliferation
The first identifier in an ECL Item Number is a number and
corresponds to the Group in which the Item is listed.
The items are further subdivided into more specific categories (or
Sub-Items) with numbering schemes that vary somewhat between
Groups. Sub-items are also identified by indentations in the text.
The second character is “-“. The third identifier
is the Category Number in the Group. After the Category
identifier, the remaining subcategory identifiers are separated by
periods. The next identifier in the Sub-Items (or
Sub-Categories) is almost always a letter. The identifiers to
follow alternate between numbers and letters. Sub-items are also
identified by indentations in the text. Determining the ECL
Item Number classification number involves looking at the text and
To identify a specific Export Control List item, the numbers and
letters of each subsequent paragraph leading to that item are
given. For example, 1-6.A.5.d.1 is an Export Control List
Item number addressing semi-conductor lasers.
There is a cheat sheet to ECL Item Number classification, which
is the Index of “A Guide to Canada’s Export
Controls”. However, based on our experience, it is not as
simple as looking at the Index. It is necessary to undertake
the classification exercise because there are times when a good can
be classified in more than one Group or Category. Due to the
fact that ECL Item Number classification is not based on an
internationally agreed upon set of rules, it is often more
complicated than H.S. classification.
Things are even more complicated. It is important for all
exporters to know that they need to know that Canada has three (3)
classification systems for goods:
The H.S. Tariff Classification Number for imports;
Canadian Export Classification Number (also called an
Export H.S. Number) for all goods to be exported; and
The ECL Item Number for restricted goods.
The H.S. Tariff Classification Number for import purposes also
remains relevant for export purposes. The H.S. Tariff
Classification Number for import purposes is determined by
reference to the Customs Tariff. The Customs Tariff
numbering system is based on the Harmonized Commodity Description
and Coding System (or Harmonized System). The H.S. Tariff
Classification Number has not been harmonized with ECL Item
The Canadian Export Classification Number is a Statistics Canada
number that is based upon the H.S. System, but only has 21
categories. You can go to an online resource of Statistics Canada.
While the H.S. Tariff Classification and the Canadian Export
Classification Number are usually the same number, there is almost
no way to use the H.S. Tariff Classification System to help with
ECL Item Number classification. The ECL Item Number
classification exercise is independent from H.S. tariff
classification. Also, just because a good is classified for H.S.
tariff classification system as a military good or ammunition does
not mean it will be on the Export Control List.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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