ECCN 9A610: military aircraft

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1. Military aircraft not on the Munitions List

Export Control Classification Number (ECCN) 9A610 on the Commerce Control List (CCL) covers military aircraft and related commodities, other than those enumerated in 9A991.a (ECCN 9A610). Paragraph .a covers military aircraft specially designed for a military use that are not enumerated in U.S. Munitions List (USML) paragraph VIII(a) (ECCN 9A610.a). A note defines military aircraft for the paragraph as the LM-100J aircraft and any aircraft specially designed for a military use that are not enumerated in VIII(a).

The term includes trainer aircraft, cargo aircraft, utility fixed wing aircraft, military helicopters and observation aircraft (ECCN 9A610.a). It also includes military non-expansive balloons and other lighter-than-air aircraft, unarmed military aircraft, unmanned aerial vehicles (UAVs) and remotely piloted vehicles (RPVs), regardless of origin or designation. Paragraph .b covers L-100 aircraft manufactured before 2013 (ECCN 9A610.b).

2. Older aircraft

A second note takes certain older aircraft out of paragraph .a (ECCN 9A610.a). It does not control military aircraft or lighter-than-air vehicles first manufactured before 1946 that do not incorporate defense articles on the USML, unless needed to meet safety or airworthiness standards of civil aviation authorities in Country Group A:1. The aircraft also must not incorporate USML weapons, unless the weapons are inoperable and incapable of being returned to operation. Military aircraft first manufactured from 1946 to 1955 that meet the conditions in paragraph .y.29 fall in the .y paragraph instead (ECCN 9A610.y).

3. Equipment paragraphs

Paragraph .e covers mobile aircraft arresting and engagement runway systems for aircraft in USML VIII(a) or 9A610.a (ECCN 9A610.e). Paragraph .f covers pressure refueling equipment, and equipment that facilitates operations in confined areas, specially designed for those aircraft (ECCN 9A610.f). Paragraph .g covers aircrew life support equipment, aircrew safety equipment and other devices for emergency escape (ECCN 9A610.g).

Paragraph .h covers parachutes, paragliders, complete parachute canopies, harnesses, platforms and electronic release mechanisms specially designed for use with those aircraft (ECCN 9A610.h). It also covers equipment specially designed for military high altitude parachutists, such as suits, special helmets, breathing systems and navigation equipment. Paragraph .i covers controlled opening equipment or automatic piloting systems designed for parachuted loads (ECCN 9A610.i). Paragraph .j covers ground effect machines, including surface effect machines and air cushion vehicles, specially designed for use by a military (ECCN 9A610.j).

4. Unmanned aircraft paragraphs

Paragraph .t covers composite structures, laminates and manufactures specially designed for UAVs in USML VIII(a) reaching 300 km or more (ECCN 9A610.t). Paragraph .u covers apparatus and devices specially designed for the handling, control, activation and non-ship-based launching of UAVs capable of a range of 300 km or more (ECCN 9A610.u). Paragraph .v covers radar altimeters for UAVs able to carry a payload of 500 kilograms or more over 300 km or more (ECCN 9A610.v).

Paragraph .w.1 covers flight control systems and attitude control equipment designed or modified for UAVs with that payload and range capability (ECCN 9A610.w). Paragraph .w.2 covers flight control servo valves for those systems, designed to operate in a vibration environment greater than 10g rms over the entire range between 20Hz and 2 kHz. Both include systems designed or modified to enable operation of manned aircraft as UAVs. For .t, .u, .v and .w.1, a note places the lower-capability equivalents in paragraph .x.

5. Catch-all and listed parts

Paragraph .x is the catch-all for specially designed parts, components, accessories and attachments of a 9A610 commodity, other than .y, or for a USML Category VIII defense article (ECCN 9A610.x). It excludes items specified elsewhere on the USML or in 9A610.y, 9A619.y or 3A611.y. Paragraph .y lists specific parts and other aircraft commodities specially designed for a military use (ECCN 9A610.y). The list includes items such as tires, galleys, passenger seats including palletized seats, and life rafts. It also covers brackets, carrying cases, controllers, chargers, mounts and propellers for UAVs and RPVs described in 9A610.a.

6. Reasons for control and exceptions

Military aircraft carry five reasons for control, adding missile technology (MT) to national security (NS), regional stability (RS), anti-terrorism (AT) and United Nations (UN) controls (ECCN 9A610). Column 1 NS and RS controls cover the entry other than 9A610.b, 9A610.x parts and components for use in a 9A610.b aircraft, and 9A610.y. MT applies to paragraphs .t, .u, .v and .w, and to UAVs and RPVs in .a capable of a maximum range of at least 300 km, regardless of payload. Items in .y face RS only for China, Russia or Venezuela.

The entry caps Shipments of Limited Value (LVS) at $1,500 and gives no access to Shipments to Country Group B countries (GBS) (ECCN 9A610). End item military aircraft in 9A610.a need approval by the Bureau of Industry and Security under section 740.20(g) before paragraph (c)(1) of License Exception Strategic Trade Authorization (STA) can be used. STA may not be used for MT-controlled items in .a with a 500 kg payload capability over at least 300 km to Country Group A:5 or A:6 destinations. STA paragraph (c)(2) is unavailable across the entry.

Missile technology controlled 600 series items may not use STA at all, with the single exception of ECCN 9A610.a (15 CFR 740.2(a)(13)). Under the same paragraph, software in 9D610.b and technology in 9E610.b are not eligible for any license exception other than License Exception Governments and international organizations (GOV) under section 740.11(b)(2).

7. Software, technology and equipment

ECCN 9B610 covers test, inspection and production equipment, and its paragraph .c covers production facilities for UAVs or drones with a range of 300 km or more (ECCN 9B610). ECCN 9D610 covers software, and its paragraph .b covers software for the development or production of listed airframe and subsystem items (ECCN 9D610). ECCN 9E610 covers technology (ECCN 9E610). Software and technical data directly related to Category VIII articles are controlled under USML paragraph VIII(i). How Category VIII treats aircraft is set out in USML Category VIII: aircraft.

Key terms

ECCN 9A610.a	Military aircraft not enumerated in USML VIII(a), including the LM-100J.
ECCN 9A610.b	L-100 aircraft made before 2013, outside the NS and RS controls.
MT paragraphs	Paragraphs .t to .w and long-range UAVs, controlled for missile technology.
ECCN 9A610.y	Specific listed aircraft items such as galleys, seats and life rafts.
USML VIII(i)	The Munitions List paragraph for Category VIII software and technical data.

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