Determination as to whether or not authorization is required to export is determined by the following criteria in the transaction: 1] what is the ECCN of the item; 2] where it is going; 3] who is the end-user; and 4] what is the end-use. While the majority of U.S. commercial exports do not require a license, the first step in this process is determining the correct classification of your item.
If your item is subject to the jurisdiction of the U.S. Department of Commerce, you must then determine if your item has a specific Export Control Classification Number [ECCN] found on the Commerce Control List [CCL]. Keep in mind that items subject to the Export Administration Regulations [EAR] that are not listed on the CCL are designated EAR99
There are three ways to determine the Export Control Classification Number [ECCN] for your product.
1. Go to the Source.
Contact the manufacturer, producer, or developer of the item you are exporting to see if they have classified their product and can provide you with the ECCN. If they have exported the item in the past, it is likely they have the ECCN. Keep in mind that ECCNs may change over time, so please review the ECCN to be sure you are in agreement.
2. Self-Classify.
In order to perform a self-classification, you must have a technical understanding of your item, and you need to be familiar with the structure and format of the CCL. The CCL is divided into ten categories, represented by the first digit of the ECCN. Each of the ten categories is divided into five product groups, represented by the second digit of the ECCN. Once the appropriate category and product group are identified, match the particular characteristics and functions of your item to one of the specific ECCNs that follow.
You can also utilize the Commerce Control List Index to navigate the CCL. Begin by searching for your item on the CCL Index. When you find a potential ECCN, you must then read through the ECCN entry on the CCL before determining if your item fits into the parameters of that ECCN. If the ECCN contains a list under the “Items” heading, broken down into subparagraph[s] it is important to read through these subparagraph[s] to determine that your item meets the technical specifications listed in the ECCN category. You may need to review more than one ECCN description before you find the correct ECCN entry.
Read Part 738 of the EAR for specific instructions on how to use the CCL. You can also access our Introduction to Commerce Department Export Controls, which is an easy-to-follow guide that walks you through the classification process step-by-step.
3. Request an official classification from the Bureau of Industry and Security [BIS].
Submit a commodity classification request online through the Simplified Network Application Process - Redesign [SNAP-R]. You must obtain a Company Identification Number [CIN] before accessing the online SNAP-R system and submitting your request.
You can also access our Guidelines to Reexport Publications to gain more insight into what information you should provide at the time of your request.
4. What if my product is not listed?
After careful review of your item against the CCL, if you are convinced your item does not fit into the parameters of any ECCN, your item may be designated as EAR99, keeping in mind it is not controlled by another agency. If this is the case, your item may be exported using the license exception NLR specifying no license is required, as long as all of the following criteria is met:
- The item is not being shipped to a sanctioned destination
- The item is not being shipped to a denied person, sanctioned entity, or prohibited end-user
- The item will not be used for a specific end-use, subject to higher controls.
For further details on these export restrictions, read Parts 736, 742, 744, and 746 of the EAR. If you still need guidance, you may contact the Outreach and Educational Services Division at [202-482-4811] or the Western Regional Office at [949-660-0144]. While BIS can provide oral advice and guidance, we cannot give definitive classifications over the phone.
Most manufacturers face at least one of these common barriers to agility. The good news is that none of them are insurmountable — even those associated with aging capital equipment. Performance Solutions by Milliken has helped hundreds of companies overcome these obstacles, dramatically increasing the agility of their plants, and improve their operational excellence. How? By implementing best practices that address the 4Ms of Machines, Manpower, Methods, and Material.
Why the 4Ms Work
We understand that complexity can sometimes be used to create the illusion of greater depth or value, but it is often the simplest of tools which aid us on our journey to make every associate a confident problem solver within their organization. We can apply these methods to address the issues they face as the front line of operations.
This can be hard to accept when a company has invested significant time and money in more complex tools and highly skilled specialists, yet we still find it to be true.
One such tool is the 4Ms of manufacturing, and most organizations we work with are familiar with the concept to some degree. Whether they know it as the 4Ms, the 5Ms, the 6Ms, Cause and Effect analysis, Fishbone diagram or Ishikawa, the basic definition is there.
What is often a surprise to many people is how powerful this simple approach can be in solving operational problems by identification and eradication of the root cause[s] by those associates closest to the issues when and where they occur.
The 4Ms
Over time, additional M’s have sometimes been added to the traditional 4Ms. Whether to direct more industry specific thinking, to demonstrate evolution or improvement of the tool, or to simply make it more complex as part of rebranding. However, the big 4 are still the same:
- huMan [Skill, Technology, Organization, Resources]
- Do our associates have the skill [and the will] to do what is expected of them safely, consistently and effectively?
- Machine [Equipment]
- Are our machines capable of safe and reliable output at the desired quality and rate? Do breakdowns, defects or unplanned stoppages inhibit their ability to meet that goal?
- Method [Process, Schedule, Procedure]
- Do we have standard work methods in place which ensure and support consistent, safe production?
- Material [Information, Raw Materials, Consumables, Quality]
- Do they meet the required specifications – are there no defects and shortages? Is excess handling or movement reduced or eliminated? Are they stored appropriately?
Exploring these 4Ms provides us with a structured framework for root cause analysis by helping us to understand how each one may have contributed to a particular issue.
4M thinking finds a place in all of our Total Productive Maintenance pillars to some extent but is most widely used as a root cause analysis mechanism. The structure it brings in identifying sources of variation, root causes of problems or improvement opportunities is invaluable as a core element of problem solving
- Safety: The 4Ms play their part in identifying root causes and improvement opportunities within the safety sub-committees.
- Focused Improvement: We use 4Ms to help structure the team’s thinking within the analyse phase of our standard DMAIC [Define, Measure, Analyse, Improve, Control] framework for focused improvement.
- Daily Management System: It is often the routine application of the 4Ms in a simple one page format that best engages and enables the problem solving capability needed to unlock the full potential of the organization.
- Planned Maintenance: The 4M framework is instrumental in reducing breakdowns by restoring the equipment, correcting basic weaknesses, and preventing issues from coming back. Working together, 4Ms helps the pillars to understand where the weaknesses are and address them through restoration and prevention.
- Quality Management: 4Ms Analysis is used to better understand our QA Matrix and address those factors which can most likely influence the generation of defects within the manufacturing processes on our journey to zero defects.
- Continuous Skills Development: A 4M analysis pinpoints improvement areas for “huMan” and “Method,” which drive CSD projects to cultivate a flexible, highly skilled workforce working and creating consistent procedures.
Of course just as a TPM implementation relies on leveraging people, process and leadership working together, the pillars working together ensures variation is reduced across all 4Ms, and there is rarely a situation where you cannot draw a link from each pillar to all 4 of the Ms.
4M Analysis
The 4M analysis is a method for evaluation which of the 4M conditions is responsible for a defect mode. Most commonly practiced is the Fishbone / Ishikawa Diagram. This is a tool designed to identify, explore, and graphically display the possible causes related to a problem or condition. This approach allows teams to focus on content of the problem, creates a snapshot of the collective knowledge and consensus of a team, and focuses the team on the cause rather than the symptom.
At Milliken & Company and other organizations guided by Performance Solutions, dramatic operations improvements are commonplace. Through implementation of the Milliken Performance System, execution of the daily management practices that support it, Zero Loss Thinking to prioritize improvement projects, and an emphasis on culture change and employee empowerment, manufacturers in many industries — automotive, chemical, aerospace, food and beverage, consumer-packaged products, paperboard and packaging, plastics and rubber, etc. — have tapped into unknown potential and agile capabilities within their organizations.