When I was writing a software rasterizer for my university class, we did culling in eye coordinates. Essentially, we use cross product to get a normal from the 3 vertices (in eye coordinates), then we dot product that normal with one of the 3 vertices (since we are in eye coordinate, that vertex is essentially a vector from eye [0, 0, 0,.1] to triangle surface). If the dot product is > 0, meaning the normal and the eye vector point in the same direction, we cull that triangle.
OpenGL however doesn't do culling in eye space, since culling is after vertex shader. So all they have are vertices in clip space. So how do they know which triangle to do culling? Our triangles, when fed into the graphic pipeline, are always in CCW order. How do some turn into CW order?