ECCN 0A606: military ground vehicles

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1. Military vehicles off the Munitions List

Export Control Classification Number (ECCN) 0A606 on the Commerce Control List (CCL) covers ground vehicles and related commodities (ECCN 0A606). Paragraph .a covers ground vehicles, whether manned or unmanned, specially designed for a military use and not enumerated or otherwise described in U.S. Munitions List (USML) Category VII (ECCN 0A606.a). Ground vehicles and related technical data in USML Category VII stay under the International Traffic in Arms Regulations (ITAR) (ECCN 0A606).

A note lists what paragraph .a includes (ECCN 0A606.a). It covers tanks and armored vehicles manufactured before 1956, not modified since 1955, that do not contain a functional weapon or one capable of becoming functional through repair. It also covers military railway trains, except those that are armed or specially designed to launch missiles, and unarmored military recovery and other support vehicles. It further covers unarmored, unarmed vehicles with mounts or hard points for firearms of .50 caliber or less, and trailers specially designed for use with Category VII or 0A606.a vehicles and not separately described in Category VII.

2. When a vehicle is specially designed for military use

A second note explains the test for paragraph .a. A vehicle is specially designed for military use when it has a structural, electrical or mechanical feature involving one or more components specially designed for military use (ECCN 0A606.a). The note lists such components as pneumatic tire casings specially designed to be bullet-proof, and armored protection of vital parts such as fuel tanks or vehicle cabs. It also lists special reinforcements or mountings for weapons, and black-out lighting. For the pre-1956 vehicles, the first note adds that modification does not include safety features required by law, cosmetic changes, or the addition of parts or components available before 1956.

3. Armored civilian-derived vehicles

Paragraph .b.1 covers unarmed vehicles derived from civilian vehicles that have all of four features (ECCN 0A606.b). They are manufactured or fitted with materials or components, other than reactive or electromagnetic armor, giving ballistic protection equal to or better than level III under National Institute of Justice standard 0108.01 of September 1985, or equivalent standards. They have a transmission providing drive to both front and rear wheels simultaneously. Their gross vehicle weight rating is greater than 4,500 kg, and they are designed or modified for off-road use.

Paragraph .b.2 covers parts and components specially designed for those vehicles that provide the same level III protection (ECCN 0A606.b). Vehicles that would otherwise fall in .b.1 but contain reactive or electromagnetic armor are subject to USML Category VII. Paragraph .b.1 does not control civilian vehicles specially designed for transporting money or valuables. Unarmed means not having installed weapons, installed mountings for weapons, or special reinforcements for weapon mounts.

4. Engines, transmissions and other commodities

Paragraph .c covers air-cooled diesel engines and engine blocks for armored vehicles that weigh more than 40 tons (ECCN 0A606.c). Paragraph .d covers fully automatic continuously variable transmissions for tracked combat vehicles (ECCN 0A606.d). Paragraph .e covers deep water fording kits specially designed for vehicles in 0A606.a or USML Category VII (ECCN 0A606.e). Paragraph .f covers self-launching bridge components, not enumerated in USML Category VII(g), specially designed for deployment by ground vehicles in Category VII or the entry (ECCN 0A606.f).

The .x catch-all reaches parts, components, accessories and attachments that are specially designed for an entry commodity, other than .b or .y, or for a Category VII defense article, and not elsewhere specified (ECCN 0A606.x). Forgings, castings and other unfinished products clearly identifiable as .x commodities by mechanical properties, material composition, geometry or function are controlled under .x. Items enumerated in USML paragraph VII(g) are subject to that paragraph.

Paragraph .y lists specific parts (ECCN 0A606.y). They include brake parts, alternators and generators, axles, batteries, bearings, cables and connectors, and cooling system hoses. They also include filters not controlled by ECCN 1A004, gaskets and o-rings, hydraulic and pneumatic fittings, latches and hinges, lighting systems and seats. Tires are included except run flat tires, and windows are included except those for armored vehicles.

5. Reasons for control and exceptions

Four reasons for control appear in the ground vehicle entry: anti-terrorism (AT), national security (NS), regional stability (RS) and United Nations (UN) (ECCN 0A606). Column 1 of both NS and RS covers everything but .b and .y, while the armored civilian-derived vehicles in .b sit at Column 2 of each. The .y parts carry an RS requirement only for China, Russia or Venezuela. AT reaches every paragraph, and UN reaches all but .y.

The value ceiling for Shipments of Limited Value (LVS) is $1,500, and Shipments to Country Group B countries (GBS) is unavailable (ECCN 0A606). Vehicles in 0A606.a cannot move under paragraph (c)(1) of License Exception Strategic Trade Authorization (STA) unless the Bureau of Industry and Security (BIS) has determined them eligible under section 740.20(g). Nothing in the entry qualifies for STA paragraph (c)(2).

6. Equipment, software and technology

ECCN 0B606 covers test, inspection and production equipment, not enumerated on the USML, specially designed for the development, production, repair, overhaul or refurbishing of 0A606 or Category VII commodities (ECCN 0B606). Commodities in 0A606.b and .y are outside its scope (ECCN 0B606). A note gives examples, including armor plate drilling machines other than radial drilling machines and armor plate planing machines. Paragraph .b covers environmental test facilities specially designed for certification, qualification or testing (ECCN 0B606.b).

ECCN 0D606 covers software for the entry’s commodities, with 0A606.b and .y excluded from its main paragraph, and software directly related to Category VII articles is controlled in USML paragraph VII(h) (ECCN 0D606). ECCN 0E606 covers technology required to produce or develop those commodities and software, or to operate, install, maintain, repair, overhaul or refurbish them (ECCN 0E606). Each has a .y paragraph for software or technology for 0A606.y items. Technical data directly related to Category VII articles is likewise controlled in USML paragraph VII(h) (ECCN 0E606). The ITAR counterpart is explained in USML Category VII: ground vehicles.

Key terms

ECCN 0A606.a	Military ground vehicles not described in USML Category VII.
ECCN 0A606.b	Unarmed civilian-derived vehicles with level III ballistic protection.
Unarmed	Without installed weapons, weapon mountings or reinforcements for mounts.
ECCN 0A606.y	Specific listed vehicle parts such as brakes, batteries and seats.
USML VII(h)	The Munitions List paragraph for Category VII software and technical data.

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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