ECCN 0A602: guns and armament

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1. What ECCN 0A602 covers

Export Control Classification Number (ECCN) 0A602 on the Commerce Control List (CCL) covers guns and armament (ECCN 0A602). Paragraph .a covers guns and armament manufactured between 1890 and 1919 (ECCN 0A602.a). Paragraph .b covers military flame throwers with an effective range less than 20 meters (ECCN 0A602.b). Paragraphs .c through .w are reserved, and the entry has no .y paragraph (ECCN 0A602).

Paragraph .x covers parts and components specially designed for a commodity in paragraph .a or .b, or for a defense article in U.S. Munitions List (USML) Category II. They must not be specified elsewhere on the USML or the CCL (ECCN 0A602.x). It does not name accessories or attachments.

2. What stays on the Munitions List

The related controls note states that modern heavy weapons such as howitzers, artillery, cannon, mortars and recoilless rifles are subject to the International Traffic in Arms Regulations (ITAR) (ECCN 0A602). Parts, components, accessories and attachments specified in USML subcategory II(j) are subject to the controls of that paragraph. Engines specially designed for a self-propelled gun or howitzer in paragraph .a or in USML Category VII are controlled under ECCN 0A606.x.

At the older end, black powder guns and armament manufactured in or before 1890, and replicas designed for use with black powder propellants, are designated EAR99 (ECCN 0A602). For foreign-made military commodities incorporating U.S.-origin 600 series items beyond a de minimis amount, the entry refers to ECCN 0A919.

3. Reasons for control

ECCN 0A602 is controlled for national security (NS), regional stability (RS), United Nations (UN) and anti-terrorism (AT) reasons (ECCN 0A602). NS and RS apply to the entire entry at Column 1, and AT applies to the entire entry at Column 1. UN controls apply to the entire entry with a reference to section 746.1 of the Export Administration Regulations (EAR).

Both Column 1 controls require a license for every destination other than Australia, Canada and the United Kingdom (15 CFR 742.4(a)(1) and 15 CFR 742.6(a)(1)). Under RS Column 1, a 600 series application gets case-by-case review to determine whether it is contrary to United States national security or foreign policy interests (15 CFR 742.6(b)(1)(i)(A)).

4. License exceptions for the entry

The entry allows Shipments of Limited Value (LVS) only up to $500, and Shipments to Country Group B countries (GBS) are not available (ECCN 0A602). None of its items may use paragraph (c)(2) of License Exception Strategic Trade Authorization (STA). The general 600 series limits also apply. No license exception covers 600 series items destined to, shipped from, or manufactured in Country Group D:5 or Hong Kong, except GOV under section 740.11(b)(2) for items destined to, or in, D:5 (15 CFR 740.2(a)(12)).

Where the destination is in Country Group D:5, an RS Column 1 application is also reviewed consistent with the section 126.1 arms embargo policy of the ITAR (15 CFR 742.6(b)(1)(i)(D)). For foreign-made items, there is no de minimis level for U.S.-origin 600 series content in paragraphs .a through .x when the item is destined for a D:5 country (15 CFR 734.4(a)(6)(i)).

5. Production equipment in 0B602

ECCN 0B602 covers test, inspection and production equipment and related commodities specially designed for the development or production of commodities in ECCN 0A602 or USML Category II (ECCN 0B602). Paragraph .a lists commodities specially designed for the development or production of items in 0A602.a or USML Category II (ECCN 0B602.a). They are gun barrel rifling and broaching machines and their tools, gun barrel rifling machines, gun barrel trepanning machines, and gun boring and turning machines. They also include gun honing machines of 6 feet (183 cm) stroke or more, gun jump screw lathes, gun rifling machines and barrel straightening presses.

Paragraph .b covers jigs, fixtures and other metal-working implements or accessories of the kinds exclusively designed for use in the manufacture of items in 0A602 or USML Category II (ECCN 0B602.b). Paragraph .c covers other tooling and equipment specially designed for production of those items (ECCN 0B602.c). Paragraph .d covers test and evaluation equipment and test models, including diagnostic instrumentation and physical test models (ECCN 0B602.d).

The entry carries the same NS, RS, UN and AT controls as 0A602 (ECCN 0B602). Its LVS limit is higher, at $3,000, and GBS is not available. STA paragraph (c)(2) may not be used.

6. Software and technology

ECCN 0D602 covers software that is specially designed to develop, produce, operate or maintain 0A602 and 0B602 commodities (ECCN 0D602). Software required for and directly related to articles in USML Category II remains subject to the ITAR. Technology and Software under Restriction (TSR) is not available for the entry, and STA paragraph (c)(2) may not be used.

ECCN 0E602 covers technology required to develop, produce, operate, install, maintain, repair or overhaul commodities in 0A602 or 0B602, or software in 0D602 (ECCN 0E602). Technical data directly related to articles in USML Category II are subject to the ITAR. The technology entry also shows Technology and Software under Restriction (TSR) as not available and closes STA paragraph (c)(2). Under the military end use rule, incorporating an item into a 600 series item such as one in 0A602 counts as a military end use (15 CFR 744.21(f)). License Exception Governments and international organizations (GOV) authorizes contract technology for a U.S. Government agency contract only where it is not development or production technology for the 600 series (15 CFR 740.11(b)(2)(vi)).

The 600 series direct product rule reaches foreign-produced items made with U.S.-origin 600 series technology or software. Under the first branch of the rule, such an item is subject to the EAR if it is itself specified in a 600 series ECCN or ECCN 0A919. It must also be destined to Country Group D:1, D:3, D:4, D:5, E:1 or E:2 (15 CFR 734.9(d)). The Munitions List side is covered in USML Category II: guns and armament.

Key terms

ECCN 0A602	Guns and armament made from 1890 to 1919, short-range military flame throwers and their parts.
EAR99	The designation given in the entry to black powder guns made in or before 1890 and their replicas.
ECCN 0B602	Gun barrel machines, tooling and test equipment for 0A602 or Category II items.
LVS $500	The limited value shipment ceiling for 0A602.
USML II(j)	The Munitions List paragraph whose parts stay under the ITAR.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

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