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License Code C64 — New Additions to the Automated Export System

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By now, we're all growing accustomed to an ever-evolving world but keeping up with changes can be challenging. Exports are no exception.

As an Automated Export System (AES) filer, you know it’s key to stay on top of Title 15 Code of Federal Regulations Part 30, the Foreign Trade Regulations and filing requirements. So, in this blog we discuss recent AES changes related to filing Electronic Export Information (EEI) – the addition of a new AES license code, its reporting guidelines, and what this means for your work.

AES Changes

The Bureau of Industry and Security (BIS) last October published an interim final rule (FR-2021-10-21) that took effect March 7 (FR-2022-01-12). The interim final rule “establishes a new control on cybersecurity items and a new License Exception ‘Authorized Cybersecurity Exports’ (ACE) that authorizes exports of these items to most destinations except in the circumstances described in the rule.”

These changes could impact the way you file shipments if you’re exporting items that fall under this BIS requirement. Plus, accurate EEI reporting is critical for export compliance, especially if exporting a shipment subject to a license requirement (under a license or license exception).

AES filers (U.S. Principal Party in Interest (USPPI) and authorized agents) need to be aware of the following changes in order to successfully report EEI:

  • Addition of two Export Control Classification Numbers (ECCNs): 4A005 and 4D004.
  • Creation of a new AES license code C64 — Authorized Cybersecurity Exports (ACE) that authorizes exports, reexports and transfers (in-country) of cybersecurity items and certain IP network surveillance products, which are not also controlled in Category 5 — Part 2 of the Commerce Control List (CCL) or for Surreptitious Listening (SL) reasons. License Exception ACE allows the export, reexport and transfer (in-country) of “cybersecurity items” to most destinations, except those listed in Country Groups E:1 and E:2 of supplement No. 1 to part 740 of the Export Administration Regulations (EAR).

How do you report this information in the AES?

To ensure AES doesn’t reject shipments, filers must adhere to the following new reporting guidelines when using AES License Code C64 Authorized Cybersecurity Exports (ACE).

  • Report AES License Code: C64 ACE.
  • Allowable ECCNs. The following ECCNs are eligible: 4A005, 4D001, 4D004, 4E001, 5A001, 5B001, 5D001, and 5E001 to the extent permitted under part 740 of the EAR and the respective ECCN entry.
  • Allowable Export Information Codes (EIC): All except ‘UG’ (Refer to Appendix E in the Automated Export System Trade Interface Requirements [AESTIR] for a complete list of the EICs).
  • Allowable Modes of Transportation: All except “70” (Fixed Transport).

For a complete list of all of the AES license codes and their reporting guidelines, refer to Appendix F of the AESTIR.

  • Have questions or want more information? Contact the BIS at:
    Outreach and Educational Services Division (Washington, D.C.): 202-482-4811.
  • Western Regional Office (Irvine, California): 949-660-0144.
  • Northern California Branch (San Jose, California): 408-998-8806.
  • Office of Technology Evaluation (Washington, D.C.): 202-482-4933.

Need assistance filing your EEI? Contact the Census Bureau’s Trade Data Collection Branch at 

1-800-549-0595, option 1, or at askaes@census.gov.


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