ECCN 0A617: miscellaneous military items

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1. A miscellaneous entry

Export Control Classification Number (ECCN) 0A617 on the Commerce Control List (CCL) covers miscellaneous equipment, materials and related commodities (ECCN 0A617). Defense articles controlled by U.S. Munitions List (USML) Category XIII, such as materials made from classified information, remain subject to the International Traffic in Arms Regulations (ITAR), with directly related technical data. For a foreign-made military commodity whose U.S.-origin 600 series content exceeds de minimis, the entry refers to ECCN 0A919.

Paragraph .a is reserved (ECCN 0A617). Paragraph .b covers concealment and deception equipment specially designed for military application, including special paints, decoys, smoke or obscuration equipment and simulators, with specially designed parts, where not controlled by USML Category XIII (ECCN 0A617.b). Paragraph .c covers ferries, bridges not described in ECCN 0A606 or USML Category VII, and pontoons, specially designed for military use (ECCN 0A617.c). Paragraph .d covers test models specially designed for the development of defense articles in USML Categories IV, VI, VII and VIII (ECCN 0A617.d).

2. Pointers to other entries

The related controls note directs several items elsewhere (ECCN 0A617). Self-contained diving and underwater swimming apparatus and related commodities are controlled under ECCN 8A620.f. Robots, robot controllers and robot end-effectors are controlled under USML Category VII and ECCNs 0A606 and 2B007.

Libraries, meaning parametric technical databases specially designed for military use with equipment on the USML or in a 600 series ECCN, follow the controls on the technical data or technology for the items they support (ECCN 0A617). Fuel cells specially designed for USML or 600 series items follow the matching 600 series ECCN. Fuel cells specially designed for satellites or spacecraft are controlled in USML Category XV.

3. The .y paragraph

Paragraph .y covers other commodities, with parts, components, accessories and attachments specially designed for them (ECCN 0A617.y). Paragraph .y.1 covers construction equipment specially designed for military use, including equipment designed for transport in aircraft in USML VIII(a) or ECCN 9A610.a. Paragraph .y.2 covers parts for that equipment, including crew protection kits used as protective cabs.

Paragraph .y.3 covers International Organization for Standardization (ISO) intermodal containers or demountable vehicle bodies, known as swap bodies, specially designed or modified for shipping or packing defense articles or 600 series items (ECCN 0A617.y). A technical note defines modified as any structural, electrical, mechanical or other change that gives a non-military item military capabilities equivalent to an item specially designed for military use. Paragraph .y.4 covers field generators specially designed for military use. Paragraph .y.5 covers power controlled searchlights and their control units, specially designed for military use, with their mounting equipment.

4. Reasons for control and exceptions

Miscellaneous items in 0A617 share four reasons for control: national security (NS), anti-terrorism (AT), regional stability (RS) and United Nations (UN) (ECCN 0A617). Everything outside .y falls under NS and RS Column 1, and the .y commodities require an RS license solely for China, Russia or Venezuela. AT applies at Column 1 to the entire entry, while UN excludes .y.

Up to $1,500, items may ship under Shipments of Limited Value (LVS), but not under Shipments to Country Group B countries (GBS) (ECCN 0A617). Paragraph (c)(2) of License Exception Strategic Trade Authorization (STA) is unavailable for 0A617 items. For .y content, foreign-made items incorporating U.S.-origin 600 series .y items have no de minimis level when headed for Country Group E:1 or E:2, Belarus, China or Russia (15 CFR 734.4(a)(6)(ii)).

5. Equipment and materials

ECCN 0B617 covers test, inspection and production equipment, and parts, specially designed for the production, development, repair, overhaul or refurbishing of items in 0A617 or USML Category XIII (ECCN 0B617). Its paragraph .a excludes items controlled by USML Category XIII(k) and does not reach 0A617.y items. A note places field engineer equipment specially designed for use in a combat zone, and mobile repair shops specially designed or modified to service military equipment, in the entry where they are not controlled by USML Category XIII(k). Those items are identified in the Wassenaar Arrangement Munitions List at 17.d and 17.j. No paragraph of 0B617 is carved out of its four controls.

ECCN 0C617 covers miscellaneous materials specially designed for military use (ECCN 0C617). Its paragraph .a covers materials, coatings and treatments for signature suppression, specially designed for military use to reduce detectability or observability, that are not controlled by USML Category XIII or ECCNs 1C001 or 1C101. Other signature suppression materials are controlled under USML Category XIII and ECCNs 1C001 and 1C101.

6. Software and technology

ECCN 0D617 covers software specially designed for the production, development, operation or maintenance of items in 0A617, other than 0A617.y, 0B617 or 0C617 (ECCN 0D617). Its .y paragraph covers specific software for 0A617.y commodities, and, as in 0A617, the NS, RS Column 1 and UN controls of the software entry exclude .y. Software directly related to USML Category XIII articles is controlled in USML paragraph XIII(l).

ECCN 0E617 covers the technology those items and software require for development, production, operation, installation, maintenance, repair, overhaul or refurbishing (ECCN 0E617). Its .y paragraph covers specific technology for 0A617.y commodities or 0D617.y software. Technical data directly related to Category XIII articles are controlled in USML paragraph XIII(l). Technology and Software under Restriction (TSR) is unavailable for both, and STA paragraph (c)(2) is closed to both. Category XIII articles are covered in USML Category XIII: materials and miscellaneous articles.

7. Wider 600 series rules

The general 600 series rules also apply to the entry. Items in the entry that go to, ship from, or were manufactured in a Country Group D:5 country or Hong Kong have no license exception. For 0A617 items destined to, or in, D:5, the exception that survives is License Exception Governments and international organizations (GOV) (15 CFR 740.2(a)(12)). RS Column 1 applications are reviewed consistent with the arms embargo policies of section 126.1 of the ITAR where the destination is in Country Group D:5 (15 CFR 742.6(b)(1)(i)(D)). U.S.-origin content from .a through .x carries no de minimis allowance in foreign-made items bound for D:5 (15 CFR 734.4(a)(6)(i)).

Key terms

ECCN 0A617.b	Military concealment and deception equipment, such as decoys and special paints.
ECCN 0A617.y	Military construction equipment, containers, field generators and searchlights.
Modified	A change giving a non-military item military capabilities equivalent to a military item.
ECCN 0C617	Signature suppression materials, coatings and treatments for military use.
USML XIII(l)	The Munitions List paragraph for Category XIII software and technical data.

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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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