ECCN 3A611: military electronics

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1. Military electronics outside the Munitions List

Export Control Classification Number (ECCN) 3A611 on the Commerce Control List (CCL) covers military electronics (ECCN 3A611). Paragraph .a covers electronic equipment, end items and systems specially designed for a military application that are not enumerated or otherwise described in a U.S. Munitions List (USML) category or another 600 series ECCN (ECCN 3A611.a). A note explains that the paragraph includes any radar, telecommunications, acoustic or computer equipment, end items or systems specially designed for military application.

Electronic items enumerated in USML Category XI or other USML categories, with directly related technical data and software, stay under the International Traffic in Arms Regulations (ITAR) (ECCN 3A611). Military-specific electronics described in another 600 series or 9x515 ECCN are controlled by that ECCN rather than by 3A611. Certain radiation-hardened microelectronic circuits are controlled by ECCN 9A515.d or 9A515.e.

2. Radar, programmed circuits and boards

Paragraphs .b through .d are reserved (ECCN 3A611). Paragraph .e covers high frequency surface wave radar that maintains the positional state of maritime surface or low altitude airborne objects of interest in a received radar signal through time (ECCN 3A611.e). It does not apply to systems, equipment and assemblies specially designed for marine traffic control.

Paragraph .f covers application specific integrated circuits and programmable logic devices programmed for 600 series items (ECCN 3A611.f). A note defines an application specific integrated circuit as an integrated circuit made for a particular application or function, whatever the number of customers. Paragraph .g covers printed circuit boards and populated circuit card assemblies, not controlled by paragraph .y, whose layout is specially designed for 600 series items (ECCN 3A611.g). Paragraph .h covers multichip modules whose pattern or layout is specially designed for 600 series items (ECCN 3A611.h).

The related controls note sends equivalents for defense articles to the USML (ECCN 3A611). Circuits and devices programmed for ITAR defense articles are in USML XI(c)(1), and boards with a layout specially designed for defense articles are in XI(c)(2). Multichip modules for defense articles are in XI(c)(3). Unprogrammed programmable logic devices are controlled under ECCN 3A001.a.7. A separate note to the entry adds that, for boards and modules, the layout of the board or assembly and the pattern and layout of the module are the only characteristics that need be evaluated under specially designed.

3. The .x and .y paragraphs

Paragraph .x governs specially designed parts, components, accessories and attachments for a 3A611 item or for an article in USML Category XI (ECCN 3A611.x). Items in a USML category or in 3A611.y are outside it, as are items in any paragraph except the .x paragraph of another 600 series ECCN. A note allows parts of a type for use with multiple platforms to be classified under 3A611.x.

Paragraph .y covers listed parts that are specially designed for any 600 series commodity or for a defense article (ECCN 3A611.y). The list begins with electrical connectors, electric fans and heat sinks, and runs through items such as joysticks, microphones, speakers, trackballs and transformers. It also covers circuits, boards and multichip modules whose layout is specially designed for a .y item of a 600 series ECCN. Later items include breakers, switches, resistors, knobs, nameplates, and hydraulic, pneumatic, fuel and lubrication gauges.

4. Reasons for control and exceptions

Military electronics in 3A611 carry national security (NS) and regional stability (RS) controls, together with anti-terrorism (AT) and United Nations (UN) controls (ECCN 3A611). NS and RS apply at Column 1 everywhere but .y, and the .y parts require RS licensing only for China, Russia or Venezuela. UN controls also leave out .y, while AT applies throughout.

For paragraphs .a, .d through .h and .x, Shipments of Limited Value (LVS) may be used up to $1,500, and Shipments to Country Group B countries (GBS) is not offered (ECCN 3A611). The entry excludes all of its items from paragraph (c)(2) of License Exception Strategic Trade Authorization (STA). The rule for .y items in 9x515 and 600 series entries requires an RS license only to China, Russia or Venezuela, with an exception for Russia relating to the International Space Station (15 CFR 742.6(a)(7)).

License exceptions are closed to 600 series items bound for, shipped from, or manufactured in a Country Group D:5 destination or Hong Kong. Where the destination or location is a D:5 country, License Exception Governments and international organizations (GOV) under section 740.11(b)(2) remains open (15 CFR 740.2(a)(12)). Applications for military electronics needing an RS Column 1 license are reviewed case by case, including the foreign policy interest of promoting human rights (15 CFR 742.6(b)(1)(i)(A)).

5. Equipment

ECCN 3B611 covers test, inspection and production commodities for military electronics (ECCN 3B611). Its paragraph .a covers test, inspection and production end items and equipment specially designed to develop, produce, repair, overhaul or refurbish items in 3A611, other than 3A611.y, or in USML Category XI. The equipment must not be enumerated in USML Category XI or controlled by another 600 series ECCN. That equipment entry carries all four reasons for control throughout, a $1,500 LVS limit and no GBS.

6. Software and technology

ECCN 3D611 covers software specially designed for military electronics (ECCN 3D611). Its paragraph .a covers software for items in 3A611, other than .y, and 3B611, and paragraph .b covers software for the technology in 3E611.b. Except for build-to-print software, STA is not available for 3D611.b. Software directly related to Category XI articles is controlled in USML Category XI(d).

ECCN 3E611 covers technology required for military electronics (ECCN 3E611). Paragraph .a covers technology for items in 3A611, 3B611 or 3D611, other than that in .b or .y. Paragraph .b covers technology for helix traveling wave tubes and for transmit/receive or transmit modules controlled by 3A611. Except for build-to-print technology, STA is not available for 3E611.b. Technical data directly related to Category XI articles is controlled in USML Category XI(d). The matching Munitions List rules appear in USML Category XI: communications, sensors and components.

Key terms

ECCN 3A611.a	Military electronic equipment not described on the USML or in another 600 series entry.
High frequency surface wave radar	The radar in 3A611.e, excluding marine traffic control systems.
Application specific integrated circuit	An application specific integrated circuit, made for a specific application or function.
ECCN 3A611.y	Listed parts such as connectors, fans and switches for any 600 series item.
USML XI(d)	The Munitions List paragraph for Category XI 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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