ECCN 4E091
RSAT'Parameters' for an artificial intelligence model trained utilizing 1026 or more 'operations.'
What This ECCN Covers
ECCN 4E091 controls the "parameters" (model weights) of advanced closed-weight artificial-intelligence models trained using a very high amount of compute — introduced in the January 2025 framework at a baseline of models trained on 10^26 or more computational "operations." It was the first U.S. export control on AI model weights and carries a worldwide license requirement for Regional Stability and Anti-Terrorism reasons.
Who needs to check this?
Developers and operators of frontier AI models, and organizations that transfer or host closed (unpublished) model weights across borders.
Compliance tip
AI controls are fast-moving — confirm the current threshold and scope against the latest BIS rules rather than relying on the original figures. Open-weight / "published" model weights (per §734.7) are excluded; for controlled closed-weight models, review License Exception AIA and the AI model-weight foreign-direct-product rule.
Control Reasons
Items controlled for regional stability reasons.
Items controlled for anti-terrorism reasons. Most items on the CCL have AT controls.
Disclaimer
This information is for reference only. For official classifications, consult BIS or a qualified export control professional.