Export Control and Sanctions Acronyms Explained: EAR, ECCN, FDPR, SDN, Entity List and More
US export controls and sanctions come with a thick layer of acronyms. News stories about Nvidia, Huawei or chip tools often use them without explanation. This glossary defines the terms that come up most, grouped by the agency or rulebook they belong to, with a note on how each one shows up in practice.
Last updated: 15 September 2026.
The agencies
BIS (Bureau of Industry and Security)
The part of the US Commerce Department that runs export controls on commercial and dual-use items, meaning goods, software and technology with both civilian and military uses. BIS writes the EAR, maintains the Entity List and issues licences. Its enforcement arm investigates violations and negotiates penalties.
OFAC (Office of Foreign Assets Control)
The Treasury Department office that administers sanctions. OFAC controls dealings with sanctioned countries, companies and people, including financial transactions. Export controls focus on items; sanctions focus on parties and money, though the two overlap often.
DDTC (Directorate of Defense Trade Controls)
The State Department office that controls exports of defence articles and services under the ITAR.
CFIUS (Committee on Foreign Investment in the United States)
An interagency committee chaired by Treasury that reviews foreign investment into US companies for national security risk. It can block deals or impose conditions.
The rulebooks
EAR (Export Administration Regulations)
The regulations BIS enforces, found at 15 CFR Parts 730 to 774. Almost every physical item, piece of software or technology in the United States is “subject to the EAR”, even if most need no licence for most destinations.
ITAR (International Traffic in Arms Regulations)
The State Department rules for military items. Items on the US Munitions List (USML) fall under ITAR rather than the EAR. ITAR is stricter, and US-origin ITAR content can taint a foreign-made product.
CCL (Commerce Control List)
The list inside the EAR that describes controlled items by technical parameters. Each entry has an ECCN.
Classification terms
ECCN (Export Control Classification Number)
A five-character code that places an item on the Commerce Control List. The first digit is the category (3 is electronics, 4 is computers, 5 is telecoms and information security). The letter is the product group (A for equipment and components, B for test and production equipment, D for software, E for technology). Advanced AI chips fall under 3A090, and computers containing them under 4A090.
EAR99
The catch-all classification for items subject to the EAR that don’t match any ECCN. Most consumer goods are EAR99. They can usually ship without a licence, except to embargoed countries, restricted parties or prohibited end uses.
TPP (Total Processing Performance)
The metric BIS uses to decide whether a chip is an advanced computing item. It is calculated from how many operations a chip can perform per second and the bit length of those operations. Under ECCN 3A090.a, a chip with TPP of 4,800 or more is controlled, as is one with TPP of 1,600 or more combined with high performance density. Chips designed for the China market, such as Nvidia’s H20, were built around these lines.
Performance density
TPP divided by the chip’s die area. BIS added it in October 2023 so that makers couldn’t escape the rules by spreading performance across a larger die.
HBM (High-Bandwidth Memory)
Stacked DRAM packaged next to AI accelerators. BIS added controls on advanced HBM in December 2024.
Party lists
Entity List
The BIS list of foreign companies, research institutes and individuals that need a licence for most or all items subject to the EAR. Each listing states a licence review policy. For many Chinese chip and AI firms that policy is a presumption of denial. Huawei and SMIC are the best-known entries.
MEU List (Military End-User List)
A BIS list of parties in China, Russia and a few other countries that BIS considers military end users. Exports of certain items to them need a licence.
UVL (Unverified List)
Foreign parties whose legitimacy BIS couldn’t confirm, usually after a failed end-use check. Exporters must do extra screening and can’t use licence exceptions for them. Parties that keep blocking checks can be moved to the Entity List.
SDN List (Specially Designated Nationals and Blocked Persons List)
OFAC’s main sanctions list. US persons generally can’t deal with anyone on it, and any of their property under US jurisdiction is frozen.
OFAC 50 Percent Rule
A company owned 50% or more, directly or indirectly and in total, by one or more SDN-listed parties is treated as blocked, even when it is not named on the list.
Affiliates Rule (BIS 50% Rule)
The BIS counterpart to the OFAC rule, issued on 29 September 2025. It extends Entity List and MEU restrictions to companies at least 50% owned by listed parties. BIS suspended it for one year on 10 November 2025. The suspension runs to 9 November 2026 unless extended.
1260H List
The Defense Department’s list of “Chinese military companies” operating in the United States, named after Section 1260H of the 2021 defence authorisation act. A listing doesn’t itself ban trade, though it restricts Pentagon contracting and carries reputational weight. Recent updates added Alibaba, Baidu and BYD.
NS-CMIC List
Treasury’s Non-SDN Chinese Military-Industrial Complex Companies List. US persons can’t buy publicly traded securities of listed companies.
Rules and mechanisms
FDPR (Foreign Direct Product Rule)
The rule that stretches US controls to items made outside the United States when they are the direct product of certain US technology or software, or made in a plant whose key equipment is such a product. It is how the US reaches chips fabricated abroad with US tools. Several versions exist, including ones specific to Huawei, to advanced computing and to supercomputer end uses.
De minimis rule
A foreign-made item is subject to the EAR if its controlled US-origin content passes a set percentage of value. The usual thresholds are 25%, or 10% for the most restricted destinations. Some advanced computing rules set the level at zero.
US persons rule
A restriction in the October 2022 chip controls that bars US citizens, residents and companies from supporting certain advanced chipmaking in China without a licence, even when no US item is exported.
Deemed export
Sharing controlled technology or source code with a foreign national inside the United States counts as an export to that person’s home country. It can require a licence for hiring and research collaboration.
Licence exception
A provision that lets certain exports go ahead without a licence if set conditions are met. Examples include LVS for low-value shipments and ENC for many encryption items.
VEU (Validated End-User)
A programme that pre-approves specific foreign facilities to receive listed items without individual licences. Samsung, SK hynix and TSMC operated China fabs under VEU status until BIS revoked it effective 31 December 2025.
TGL (Temporary General License)
A short-term authorisation BIS issues to ease the transition when a new rule would otherwise disrupt trade overnight.
Is-informed letter
A letter from BIS telling a specific exporter that a licence is now required for certain transactions. BIS has used these to impose restrictions on individual companies quickly, as with Nvidia’s H20 in 2025.
Red flags
Warning signs BIS expects exporters to investigate before shipping, such as a customer unwilling to state the end use or a delivery address that doesn’t fit the buyer’s business.
Multilateral and foreign regimes
Wassenaar Arrangement
A 42-member forum that agrees control lists for conventional arms and dual-use goods. Its decisions need consensus, and Russia’s membership has limited progress since 2022, so the US has increasingly coordinated chip controls directly with Japan and the Netherlands.
Outbound Investment Security Program
Treasury rules in force since 2 January 2025 that bar or require notification of certain US investments in Chinese companies working on semiconductors, quantum technology and AI.
China’s Unreliable Entity List
A Commerce Ministry (MOFCOM) list of foreign companies that Beijing says harm Chinese interests. Listed firms can face trade and investment bans. US defence contractors are frequent targets.
China’s Export Control Control List
That is the official English name. Under its 2020 Export Control Law, China keeps a list of foreign end users barred from receiving Chinese dual-use items. In 2026 it added US firms including MP Materials and USA Rare Earth, and the measures reach third-country companies that re-export Chinese-origin goods to them.