Deemed Exports FAQs - 600 Series Items
Q.1: What is the “600 series”?
A.1: "600 series" refers to ECCNs in the "xY6zz" format on the Commerce Control List (CCL). Items controlled under the "600 series" were previously controlled on the United States Munitions List (USML) or are covered by the Wassenaar Arrangement Munitions List (WAML) and include certain items formerly classified under ECCNs ending in -018. The "6" indicates the entry is a munitions entry on the CCL. The "x" represents the CCL category (0 through 9) and "Y" the CCL product group (A through E). In most cases, the "zz" represents the WAML category. The "600 series" constitutes the munitions ECCNs within the larger CCL.
Q.2: Have “600 series” ECCNs been added to the CCL?
A.2: Yes. The table below shows the new ECCNs that have been added to the EAR since the export control reform effort began in 2013. The table shows the dates on which the final rule that implemented the ECCNs was published, and the dates on which the final rules became effective. The last column in the table shows the USML category that is related to the new ECCNs.
Items |
USML Cat. |
ECCNs |
P: Proposed Rule F: Final Rule |
Effective Date |
Firearms |
I |
N/A |
P |
|
Guns and Armament |
II |
N/A |
P |
|
Ammunition |
III |
N/A |
P |
|
Rockets/Missile |
IV |
0A604, 0B604, 0D604, 0E604 9A604, 9B604, 9D604, 9E604 |
July 1, 2014 |
|
Explosives/Energetic Materials |
V |
1B608, 1C608, 1D608, 1E608 |
July 1, 2014 |
|
Vessels/Submersibles |
VI XX |
8A609, 8B609, 8C609, 8D609, 8E609 8A620, 8B620, 8D620, 8E620 |
P: USML VI/XX F: USML VI/XX; |
January 6, 2014 |
Military Vehicles |
VII |
0A606, 0B606, 0C606, 0D606, 0E606 |
January 6, 2014 |
|
Aircraft |
VIII |
9A610, 9B610, 9C610, 9D610, 9E610 |
October 15, 2013 |
|
Military Training Equipment and Training |
IX |
0A614, 0B614, 0D614, 0E614 |
July 1, 2014 |
|
Personal Protective Equipment |
X |
1A613, 1B613, 1D613, 1E613
|
July 1, 2014 |
|
Military Electronics |
XI |
3A611, 3B611, 3D611, 3E611 9A620, 9B620, 9D620, 9E620
|
P1: USML XI; CCL 3Y611/9Y620 P2: USML XI; CCL 3Y611/9Y620 |
December 30, 2014 |
Sensors/Night Vision |
XII |
7A611, 7B611, 7D611, 7E611 |
P1: USML XII; CCL 6Y615/7Y611 |
December 31, 2016 |
Auxiliary Military Equipment |
XIII |
0A617, 0B617, 0C617, 0D617, 0E617 |
January 6, 2014 |
|
Toxicological Agents |
XIV |
1A607, 1B607, 1C607, 1D607, 1E607 |
December 31, 2016 |
|
Spacecraft Systems |
XV |
9A515, 9B515, 9D515, 9E515 |
Rad Hard ICs: 6/27/14 All Other Items: 11/10/14 |
|
Nuclear |
XVI |
N/A |
F: USML XVI |
July 1, 2014 |
Classified |
XVII |
N/A |
F: April 16, 2013 |
October 15, 2013 |
Directed Energy Weapons |
XVIII |
6B619, 6D619, 6E619 |
December 31, 2016 |
|
Gas Turbine Engines |
XIX |
9A619, 9B619, 9C619, 9D619, 9E619 |
October 15, 2013 |
|
Not Otherwise Enumerated |
XXI |
N/A |
F: April 16, 2013 |
October 15, 2013 |
Q:3: Are there additional “600 series” ECCNs to be added to the CCL?
A.3: Yes, items from USML categories IV, V, IX, and X: military training equipment, energetic materials, personal protective equipment, shelters, articles related to launch vehicles, missiles, rockets, military explosives, and related items have been added to the "600 series" of the CCL. To follow transfers from the ITAR USML to the EAR CCL, see the ECR dashboard at
Subsequent final rules will be published creating additional "600 series" entries that correspond with revised USML Categories. After the publication date and prior to the effective date of each final rule, you may pre-position applications for Commerce licenses for items that will transition, as well as submit classification requests to BIS for items that you believe will move to the "600 series." However, until the effective date, you must follow the existing ITAR and EAR.
Q.4: What is the classification of parts and components that are (a) not enumerated or otherwise described on the USML and (b) common to the C-130 and L-100/L-382 aircraft but not any other aircraft?
The manufacturer of the aircraft, the Lockheed Martin Corporation, and the Department of State have confirmed that all models and versions of both types of aircraft are within the scope of USML Category VIII(a)(14) (22 CFR § 121.1). This means that parts, components, accessories, and attachments for use in or with the C-130 or L-100/L-382 aircraft that are not enumerated or otherwise described on the USML are controlled under ECCN 9A610.x, or if specifically identified in 9A610.y, controlled under 9A610.y, unless one of the release provisions in paragraph (b) to the EAR's definition of "specially designed" applies (15 CFR § 772.1). In addition, the Rolls Royce 501 D engine used on L-100/L-382 aircraft and other aircraft in production controlled under ECCN 9A991, is controlled under ECCN 9A991.d. Parts common to the T-56 military engine used on the C-130 and other military aircraft and the 501 D used on the L-100/L-382 aircraft are also controlled under ECCN 9A991.d.
Q.5: What is the classification of parts and components that are (a) not enumerated or otherwise described on the USML, (b) common to the C-130 and L-100/L-382 aircraft and also common to aircraft in production controlled under ECCN 9A991, and (c) not....
Q.5: What is the classification of parts and components that are (a) not enumerated or otherwise described on the USML, (b) common to the C-130 and L-100/L-382 aircraft and also common to aircraft in production controlled under ECCN 9A991, and (c) not enumerated or described on the CCL other than in 9A991.d?
ECCN 9A991.d.