Record why a part is classified the way it is — the parameters read, the technical note relied on, the date and the person — and leave the determination to a named classifier.
A part is classified by a named person, and the file keeps the parameters that produced the answer.
02
A self-classification carries no prescribed signature, so the reasoning is all a later reader can test.
Reason
03
A deadline can carry no signatory at all — the 1 February encryption report and the quarterly 743.9 one.
04
A record meets 762.5 only with an audit trail, written procedures and retrieval by party or country.
05
A transaction ends, and 762.6 runs five years from the latest of export, reexport or diversion.
Decide
06
A rule is unenforced and still codified — 740.27, 740.28, 740.29 and ECCN 4E091 were never removed.
07
A legacy procedure asks for an encryption registration; Supplement No. 5 to Part 742 is [Reserved].
Out
08
A file is kept whole — the parameters, the screens run, the drafts and the person who reasoned it.
09
Execute write actions only inside the approval boundaries agreed during implementation.
→Product statement
The agent assembles the parameters and keeps the file; a named person classifies the part, decides whether a licence is required, signs and files, and the exporter answers for it.
Example workflow
One part, parameters to signature
AgentHuman
1Part reaches the queueA new part number, a design change, a new destination, or a release to a foreign person on site
2Parameters assembledDatasheet values, the technical note relied on, the buyer, the destination and the source behind each
3Rationale draftedThe parameters read, the classification proposed, and what would change the answer
4Controls appliedList-currency checks, parameter-source checks, licence-clock checks and completeness confidence
No human action required
Stages 1 to 4 run unaided, and nothing is classified at any of them — the agent is assembling, and the trade compliance lane opens at the completeness gate.
5DecisionBranches at the completeness gate
Parameters sourced
Goes to the trade compliance lead to classify.
Anything thin
Adds an export counsel read first.
Trade compliance review
The file is held with its parameters, its screens and its gaps.
Record the classification · Append evidence · Send to counsel
Classified — by a named person▼
6Item master and order records updatedOnly where write access and export policy allow it
7Outcome evaluatedScreen currency, parameter completeness, counsel corrections and what a later review found
Corrections
Each counsel correction is counted in the evaluation.
What should not run autonomously
Human approval stays in control
Outside the boundary — human approval required8 items
Determining the ECCN, or that a part is EAR99.
Deciding that no licence is required.
Signing Block 25 or a Form BIS-711 statement.
Filing in SNAP-R, in AES or with any authority.
Automation boundaryAgent acts unaided
✓Assemble the parameters and name the source of each.
✓Re-run the end-user screen against every list currently on record.
✓Draft the rationale, the note relied on and the date.
✓Diarise the 750.7(g) licence validity against the employee tenure.
Nothing is classified or filed except by a named person, inside the agreed boundaries.
Judging that a listed party has left a screen.
Telling a customer that no authorisation is needed.
Deciding that a release on site is object code, not source.
Changes to screening rules, clocks or licence packages.
Example output
One part, annotated
Five years after the export this file is the reasoning, and no signature was ever prescribed for it.
Classification file · single partIllustrative example
Part
Written up as
Parameters
Note of record
Confidence
Held for
Encrypting network module
Proposed 5A992, the 740.17(b)(1) route
Read 19 August 2026
Producer note, revision on file
Held unclassified
The trade compliance lead, in person
As receivedTaken from the datasheet revision on file and the classification the producer publishes.
What the file holdsThe parameters readThe producer noteThe end-user screen
Why no classification hereStrict liability sits on the exporter, and 748.3 makes a CCATS no ruling on scope.
ActionRecord the classificationAppend evidenceSend to counsel
What the score decidesBelow the configured threshold the file picks up a counsel read before.
Value
Where AI adds value
The same four claims, placed at the point in the workflow where each one applies.
Where the value landsValue 01 – 04
Every partFrom the item master
03Evidence
Screen the party, not just the part
Shipment screening is our transportation agent, HTS origin our manufacturing one, and the FCC covered list a separate page.
01Approved path
The rationale is the product
Nothing is signed on a self-classification, yet Block 25 must be signed by hand, and a BIS-711 responsible official cannot delegate.
02Human review
Where the exposure now reaches
The Affiliates Rule is stayed to 9 November 2026 and reimposes on 10 November 2026; the separate OFAC fifty-per-cent rule was never suspended.
04Build an evidence trail
The part, the parameters that drove the classification and the person who reasoned it stay on file.
Integrations
Typical integrations
Five system groups connect to the same agent. Which of them are in scope is decided in discovery.
Filing systemsSNAP-R · AES / EEI Licence and CCATS records
Screening listsEntity List · MEU List SDN · Unverified List
Product and engineeringPLM · item master Datasheets · technical notes
Agent
Export classification & licence
Reads the parameters Builds the file Holds for the classifier
Order and shipping systemsERP · order management Forwarder records
A destination-level rationale-completeness figure can read clean while one route absorbs most of the corrections. Nestack reports the counsel-correction rate by destination, not only in total.
Slice performance — reported separately, not only in aggregateIllustrative example
Slice
Failure rate
Lift
Lift vs. threshold
Status
Third-country assembly routes
7.9%
3.7×
Review
Uncontrolled parts to listed fabs
5.6%
2.6×
Review
Deemed exports on site
3.5%
1.6×
Watch
Direct A:5 destinations
2.3%
1.1×
Normal
Bar: counsel-correction-rate lift vs. direct A:5 baseline · scale 0–4.0× · tick marks the 2.0× review threshold2 of 4 slices over threshold
Evidence-linked improvement
What an unreconstructable file costs
A cycle closes when the uncontrolled part to a listed party is a regression case. That suite is what the next classification written is measured against.
Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn
01Detect
Counsel-correction rate rises on one destination.
02Diagnose
The brush that carried no control number and went to a listed fab anyway is read back until one cause remains.
03Improve
The change is numbered, and the parts that provoked it are filed underneath.
04Verify
One part case still red will hold the whole release.
05Learn
It becomes a permanent case, and the screening rules change with it.
Learn → DetectThe return edge. The next classification is measured against a suite one case longer.
Typical build scope
Twelve workstreams across six weeks
The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, file assembly, evaluation, integration, then production validation and handover.
WorkstreamWeek 1Week 2Week 3Week 4Week 5Week 6
01Classification-workflow discovery and boundary work.
02Item-master, PLM and datasheet sources.
03Control-parameter, screening-list and clock mapping.
04Parameter ingestion and normalisation.
05Technical-note and revision binding.
06Completeness scoring and counsel routing.
07Classifier release workflow.
08Screening and ERP integration.
09Parameter and screening cases.
10Guardrails and licence controls.
11Classification-trail instrumentation.
12Deployment, documentation and Agent Care handover.
12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallelFinal scope and sequence confirmed in discovery
Engagement tiers
What each tier includes
Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.
Capability✓ in scope · — not at this tierPilotOne product family, one destinationProductionProduction screening workflowAdvancedMultiple families / destinations
Introduced at Pilot
File assembly to your rules✓✓✓
Named-classifier release✓✓✓
Parameter-provenance baseline✓✓✓
Introduced at Production
Reporting by destination—✓✓
Release workflow in your systems—✓✓
Approved write-back—✓✓
Screening-system integration—✓✓
Introduced at Advanced
Multi-list screening duties——✓
Cross-site deemed-export packs——✓
High part volume——✓
Multi-list end-user controls——✓
Build priceFrom $5,000From $8,000Custom quote
Final build priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.
Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.
What we need from you
What you bring, and what we build with it
Each input maps to a piece of build scope and a week in the delivery timeline.
You bringWe build with it
01Your part records and item master→Parameter ingestion and part mappingWeek 1
02Representative parts and technical notes→File baseline, note binding and rationale captureWeek 2
03Your screening lists and licence conditions→Control-parameter, screening-list and clock mapping and the automation boundaryWeek 1
04Access to relevant APIs, feeds or exports→Item-master, PLM and screening assessment, then integration setupWeek 2
05Classifications you would not want re-derived→Parameter cases and failure-mode testingWeek 4
06What no classification file may conclude→Completeness scoring, counsel routing, guardrails and release controlsWeek 3
07A named trade compliance lead to classify→Classifier release workflow, then pilot and production validationWeeks 5–6
Nothing else is requiredDeployment, documentation and Agent Care handover are ours.
Delivery timeline
Four phases across six weeks
Every bar is the true working span of one phase, so the fifth week has to hold a pair of them here.
PhaseW1W2W3W4W5W6
DiscoveryW1
BuildW2 – W3
EvaluateW4 – W5
Pilot & LaunchW5 – W6
Week focusW1Classification workflow discovery, parameter mapping and the automation boundaryW2Source integration and the parameter baselineW3File assembly, screening logic and release controlsW4Evaluation suite, parameter cases and failure-mode testingW5Screening integration, pilot parts and targeted correctionsW6One export quarter run under the empowered trade compliance lead, then Agent Care handover
Reading the bandA bar covers only the weeks its own work is named in. The doubled fifth week is real work, not padding.
At the end of W6Once the classification record validates, Agent Care takes over the watch.
DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.
Next step · Electronics AI agent
Build an export classification agent around a file that nobody signs.
Show us how a part reaches classification today and who reasons it on 1 September. Who signed your last self-classification? Nobody did, because the EAR prescribes no signature on one, which is why the dated reasoning is the only part of it a reader can test.
