ECCN 0A614: military training equipment

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1. Training equipment on the Commerce list

Export Control Classification Number (ECCN) 0A614 on the Commerce Control List (CCL) covers military training equipment (ECCN 0A614). Its paragraph .a covers equipment specially designed for military training that U.S. Munitions List (USML) Category IX does not enumerate or otherwise describe (ECCN 0A614.a). Defense articles in USML Category IX, and technical data including software directly related to them, fall under the International Traffic in Arms Regulations (ITAR) (ECCN 0A614).

A note lists what the entry includes (ECCN 0A614). It covers operational flight trainers, radar target trainers, flight simulators for aircraft under ECCN 9A610.a, human-rated centrifuges, and radar trainers for radars under ECCN 3A611. It also covers instrument flight trainers for military aircraft, navigation trainers for military items, target equipment and armament trainers. Military pilotless aircraft trainers, mobile training units and training equipment for ground military operations complete the list. A second note states that the entry does not apply to equipment specially designed for training in the use of hunting or sporting weapons.

2. Parts and shared simulator parts

Nothing is listed in paragraphs .b through .w, and there is no .y paragraph (ECCN 0A614). Paragraph .x takes in specially designed parts, components, accessories and attachments for training commodities in the entry or an article in USML Category IX, and not specified elsewhere on the USML (ECCN 0A614.x).

The related controls note addresses parts common to a simulator and to the system it simulates (ECCN 0A614). It covers parts, components, accessories and attachments common to a simulator under 0A614.a and to a simulated system or end item on the USML or elsewhere on the CCL. Those items are controlled under the same USML category or ECCN as those of the simulated system or end item. For foreign military commodities built with above de minimis U.S.-origin 600 series content, the note refers to ECCN 0A919.

3. Reasons for control

Training equipment is controlled for United Nations (UN), anti-terrorism (AT), regional stability (RS) and national security (NS) reasons across the whole entry (ECCN 0A614). NS, RS and AT apply at Column 1. The NS and RS Column 1 controls exempt only Australia, Canada and the United Kingdom from the license requirement (15 CFR 742.4(a)(1) and 15 CFR 742.6(a)(1)).

An application needing an RS Column 1 license gets case-by-case review against the national security and foreign policy interests of the United States (15 CFR 742.6(b)(1)(i)(A)). For D:5 destinations, the arms embargo policy in section 126.1 of the ITAR also shapes that review (15 CFR 742.6(b)(1)(i)(D)).

4. License exceptions

The entry permits Shipments of Limited Value (LVS) to $1,500 but not Shipments to Country Group B countries (GBS) (ECCN 0A614). Paragraph (c)(2) of License Exception Strategic Trade Authorization (STA) is closed to training equipment. Any use of STA for 600 series items is limited to persons located in the United States or a Country Group A:5 country and, for natural persons, nationals of those countries. The shipment must also satisfy one of the listed conditions (15 CFR 740.20(b)(3)(ii)).

For Hong Kong and Country Group D:5, whether as destination, place of shipment or place of manufacture, no license exception is available. Training equipment destined to, or in, D:5 keeps access to License Exception Governments and international organizations (GOV) under section 740.11(b)(2) (15 CFR 740.2(a)(12)). Elsewhere, only a closed list of license exceptions may be used for 600 series items (15 CFR 740.2(a)(13)).

5. Equipment, software and technology

ECCN 0B614 covers test, inspection and production equipment for military training equipment, and specially designed parts for it (ECCN 0B614). Its paragraph .a covers test, inspection and other production equipment specially designed for developing, producing, repairing, overhauling or refurbishing commodities in 0A614 or USML Category IX (ECCN 0B614.a). Its paragraph .x covers parts specially designed for 0B614 commodities. The entry carries NS, RS, AT and UN controls, LVS up to $1,500, no GBS and no STA under paragraph (c)(2).

ECCN 0D614 covers software specially designed for the development or production, or the operation or maintenance, of commodities in 0A614 or 0B614 (ECCN 0D614). Software directly related to Category IX articles is controlled in USML paragraph IX(e). ECCN 0E614 covers technology required for development and production, and for operation, installation, maintenance, repair, overhaul or refurbishing, of items in 0A614, 0B614 or 0D614 (ECCN 0E614). Technical data directly related to Category IX articles is controlled in USML paragraph IX(e). Neither the software entry nor the technology entry offers Technology and Software under Restriction (TSR), and neither allows STA paragraph (c)(2).

6. Foreign-made items

Reexports of foreign-made military commodities classified under ECCN 0A919 need a license to all destinations except Australia, Canada and the United Kingdom (15 CFR 742.6(a)(3)). Reexports as part of a military deployment by a unit of a Country Group A:1 government or of the United States are excepted. In both 0D614 and 0E614, paragraph .b is reserved (ECCN 0D614 and ECCN 0E614).

Foreign-made goods containing U.S.-origin 600 series content from paragraphs .a through .x get no de minimis allowance when bound for a Country Group D:5 country (15 CFR 734.4(a)(6)(i)). A foreign-produced item can also be subject to the Export Administration Regulations (EAR) under a direct product rule. Under the first branch, such a product comes from U.S.-origin 600 series technology or software, is classified in a 600 series ECCN or ECCN 0A919 itself, and is headed to a listed country group (15 CFR 734.9(d)). Training articles that remain on the Munitions List are described in USML Category IX: training equipment and training.

7. Completing the chain

Training equipment shipped under STA remains subject to a note on completing the chain (15 CFR 740.20). Each item has to end up with an eligible ultimate end user or under some other EAR authorization. The duty survives incorporation of the item into a foreign-made product that may have left the EAR. Military end use, under the rule for certain countries, also includes incorporation into 600 series items such as those in this entry (15 CFR 744.21(f)).

Key terms

ECCN 0A614.a	Equipment specially designed for military training and not in USML Category IX.
Simulator parts rule	Shared parts follow the classification of the simulated system or end item.
Sporting exclusion	Training equipment for hunting or sporting weapons is outside the entry.
ECCN 0B614	Test, inspection and production equipment for training equipment.
USML IX(e)	The Munitions List paragraph for Category IX software and technical data.

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