ECCN 1A613: armor and protective equipment

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1. Armored and protective equipment

Export Control Classification Number (ECCN) 1A613 on the Commerce Control List (CCL) covers armored and protective equipment and related commodities (ECCN 1A613). Defense articles in U.S. Munitions List (USML) Category X or XIII, such as materials made from classified information, are governed by the International Traffic in Arms Regulations (ITAR), together with directly related technical data. The entry refers to ECCN 0A919 for foreign-made military commodities containing more than a de minimis share of U.S.-origin 600 series content.

Paragraph .a covers metallic or non-metallic armored plate specially designed for military use and not controlled by the USML (ECCN 1A613.a). A note sends body armor plates to 1A613.d.2 and USML Category X(a)(1). Paragraph .b covers shelters specially designed for listed protective purposes, including shelters that provide ballistic protection for military systems (ECCN 1A613.b).

2. Military helmets

Paragraph .c covers military helmets providing less than National Institute of Justice (NIJ) Type IV or equivalent protection, other than helmets in 1A613.y.1 (ECCN 1A613.c). Police helmets are controlled under ECCN 0A979, and other military helmets under USML Category X(a)(5) and (a)(6). Paragraph .c does not apply to helmets first manufactured before 1970 that are neither designed or modified to accept, nor equipped with, items on the USML or in another 600 series ECCN.

Conventional military steel helmets fall in paragraph .y.1 instead (ECCN 1A613.y). The same pre-1970 exclusion applies to them. For other military helmet components or accessories not specified in 1A613.c, the related controls note points to the relevant ECCN or USML entry (ECCN 1A613).

3. Body armor

Paragraph .d.1 covers soft body armor and protective garments manufactured to military standards or specifications, or their equivalents. The protection they give must be equal to or less than NIJ level III under NIJ 0101.06 of July 2008, or equivalent standards (ECCN 1A613.d). For that paragraph, military standards or specifications include, at a minimum, specifications for fragmentation protection. Paragraph .d.2 covers hard body armor plates providing ballistic protection equal to NIJ level III.

A note marks the boundaries (ECCN 1A613.d). Soft body armor not manufactured to military standards, and hard plates providing less than NIJ level III, are controlled under ECCN 1A005. Body armor providing NIJ Type IV protection or greater is controlled under USML Category X(a)(1). The entry’s definitions note identifies the standards as NIJ Standard 0101.06 for body armor and NIJ Standard 0108.01 for protective materials (ECCN 1A613).

4. Diving suits, other equipment and parts

Paragraph .e covers atmospheric diving suits specially designed for rescue operations for submarines controlled by the USML or the CCL (ECCN 1A613.e). Paragraph .f covers other personal protective equipment specially designed for military applications, not controlled by the USML or elsewhere on the CCL (ECCN 1A613.f). Anti-gravity suits and pressure suits capable of operating above 55,000 feet are controlled in ECCN 9A610.g (ECCN 1A613).

Paragraph .x takes specially designed parts, components, accessories and attachments, where they are for a 1A613 commodity other than .y, or for an article in USML Category X, and not controlled elsewhere in the USML (ECCN 1A613.x). It includes forgings, castings and other unfinished products clearly identifiable by mechanical properties, material composition, geometry or function as .x commodities.

5. Reasons for control and exceptions

Protective equipment in 1A613 is subject to regional stability (RS), national security (NS), anti-terrorism (AT) and United Nations (UN) controls (ECCN 1A613). Other than the steel helmets in .y, every paragraph sits at Column 1 for NS and RS. The .y helmets only require an RS license for China, Russia or Venezuela. UN controls skip .y, and AT controls cover the whole entry. The entry allows Shipments of Limited Value (LVS) up to $1,500, offers no Shipments to Country Group B countries (GBS), and closes paragraph (c)(2) of License Exception Strategic Trade Authorization (STA).

Helmets and body armor have a special place in the license exception rules. For helmets in .c and armor in .d, the D:5 bar gives way to two exceptions: Temporary imports, exports, reexports and transfers in-country (TMP) under section 740.9(a)(11), and Baggage (BAG) under section 740.14(h)(2) (15 CFR 740.2(a)(12)(ii)). For countries outside D:5, TMP lets a U.S. person take one set of 1A613.d body armor abroad temporarily, and the set may include one 1A613.c helmet. The armor must travel with the person’s baggage and be for that person’s exclusive use (15 CFR 740.9(a)(11)(i)). For D:5 countries other than Iraq, the traveler must be with the U.S. Government on official business or be supporting a U.S. Government contract (15 CFR 740.9(a)(11)(ii)(B)).

The general 600 series limits still apply to other paragraphs of the entry. Outside paragraphs .c and .d, a 1A613 item tied to Hong Kong or a Country Group D:5 country, as destination, shipping point or place of manufacture, has no license exception. Protective items going to, or located in, D:5 can still use License Exception Governments and international organizations (GOV) (15 CFR 740.2(a)(12)).

6. Equipment, software and technology

ECCN 1B613 covers equipment for testing, inspection and production that is specially designed to develop, produce, repair, overhaul or refurbish 1A613 or USML Category X items (ECCN 1B613). Paragraph .a covers such equipment not covered by USML Category X(c), and paragraph .b covers plasma pressure compaction equipment specially designed for the production of ceramic or composite body armor plates. All four reasons for control cover that entry without exception, it has a $1,500 LVS limit and no GBS, and STA paragraph (c)(2) is closed (ECCN 1B613). For the software and technology entries 1D613 and 1E613, Technology and Software under Restriction (TSR) is shown as unavailable (ECCN 1D613 and ECCN 1E613).

ECCN 1D613 covers software specially designed for developing, producing, operating or maintaining 1A613 or 1B613 items, with a .y paragraph for software for 1A613.y items (ECCN 1D613). ECCN 1E613 covers technology required for the development or production of those items, and for their operation, installation, maintenance, repair, overhaul or refurbishing those items (ECCN 1E613). Software and technical data directly related to Category X articles are controlled under USML paragraph X(e). Protective articles on the Munitions List are covered in USML Category X: personal protective equipment.

Key terms

ECCN 1A613.c	Military helmets below NIJ Type IV protection, other than steel helmets in .y.1.
ECCN 1A613.d	Military-standard soft armor to NIJ level III and hard plates at NIJ level III.
ECCN 1A005	The entry for non-military soft armor and plates below level III.
USML X(a)(1)	The Munitions List paragraph for body armor at NIJ Type IV or greater.
TMP for body armor	Temporary export of one set of armor and one helmet by a U.S. person.

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.

How Sentfore supports this

Protective equipment is basic kit for teams working abroad. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.