ECCN 9A619: military gas turbine engines

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1. What the entry covers

Export Control Classification Number (ECCN) 9A619 on the Commerce Control List (CCL) covers military gas turbine engines and related commodities (ECCN 9A619). Paragraph .a covers military gas turbine engines specially designed for a military use that are not controlled in U.S. Munitions List (USML) Category XIX(a), (b), (c) or (d) (ECCN 9A619.a). A note defines military gas turbine engines as gas turbine engines specially designed for end items in USML Categories VI, VII or VIII, or under ECCNs 0A606, 8A609 or 9A610. Engines and related technical data in USML Category XIX continue to be governed by the International Traffic in Arms Regulations (ITAR) (ECCN 9A619).

One engine family is placed elsewhere by name. Gas turbine engines designated 501-D22 are controlled in ECCN 9A991.d regardless of the aircraft type into which they will be installed (ECCN 9A619).

2. Controls, hot sections and monitoring

Paragraph .b covers digital engine controls, such as Full Authority Digital Engine Controls and Digital Electronic Engine Controls, specially designed for engines in the entry (ECCN 9A619.b). Paragraph .c covers hot section components specially designed for engines in 9A619.a (ECCN 9A619.c). They are combustion chambers and liners, high pressure turbine blades, vanes, disks and related cooled structure, and the cooled low pressure equivalents. Cooled augmenters and cooled nozzles are also included.

Paragraph .d covers uncooled turbine blades, vanes, disks and tip shrouds specially designed for engines in 9A619.a (ECCN 9A619.d). Paragraph .e covers combustor cowls, diffusers, domes and shells for those engines (ECCN 9A619.e). Paragraph .f covers engine monitoring systems, meaning those that conduct prognostics, diagnostics and health monitoring, specially designed for engines and components in the entry (ECCN 9A619.f). Paragraphs .g through .w are reserved.

3. Engine parts in .x and .y

The engine entry’s .x paragraph controls specially designed parts, components, accessories and attachments for a 9A619 commodity, other than 9A619.c, or for a USML Category XIX defense article (ECCN 9A619.x). Anything specified elsewhere on the USML, or in 3A611.y, 9A610.y or 9A619.y, is outside it. Parts specified in USML subcategory XIX(f) stay under that paragraph.

The .y list names specific parts specially designed for 9A619 or 9A610 commodities, or for defense articles in USML Category VIII or XIX (ECCN 9A619.y). The list covers oil tanks and reservoirs, oil lines and tubes, and fluid hoses and lines with their fittings, couplings and brackets. It also covers fluid filters and filter assemblies, clamps, shims, identification plates and nameplates, fluid manifolds, and check valves for fluid systems. In paragraph .y, the term fluid includes liquids and gases (ECCN 9A619).

4. Reasons for control and exceptions

Engines in 9A619 are controlled for anti-terrorism (AT), United Nations (UN), national security (NS) and regional stability (RS) reasons, with no missile technology control (ECCN 9A619). Except for the .y items, the entry sits at Column 1 of NS and of RS. RS reaches .y only for China, Russia or Venezuela. UN covers all but .y, and AT covers everything.

Engines and parts may ship under Shipments of Limited Value (LVS) up to $1,500, while Shipments to Country Group B countries (GBS) is not available (ECCN 9A619). No item in 9A619 may use paragraph (c)(2) of License Exception Strategic Trade Authorization (STA). Some engines and engine items in 9A619.a, .b and .c can count as 600 Series Major Defense Equipment when they pass the cost thresholds in the definition (15 CFR 772.1). A contract value test applies outside Country Group A:5. Once a contract holds $14,000,000 or more of that equipment, its 600 series items lose all license exceptions but License Exception Governments and international organizations (GOV) for U.S. Government end users (15 CFR 740.2(a)(15)).

Inside Country Group A:5, the trigger rises to $25,000,000 or more of such equipment in the contract (15 CFR 740.2(a)(16)). STA is likewise unavailable for that equipment when its contract value passes $25,000,000 (15 CFR 740.20(b)(3)(iv)).

5. Equipment

ECCN 9B619 covers equipment for testing, inspecting and producing engines and related commodities, where specially designed for 9A619 or USML Category XIX items (ECCN 9B619). Its paragraph .a covers test, inspection and production equipment for the production, development, operation, installation, maintenance, repair, overhaul or refurbishing of 9A619 or Category XIX commodities, other than 9A619.y (ECCN 9B619.a). Its paragraph .b covers equipment, cells or stands specially designed for testing, analysis and fault isolation of engines and their systems, components and parts in 9A619, other than 9A619.y, or in Category XIX (ECCN 9B619.b). Its .y paragraph covers bearing pullers. NS and RS Column 1 apply except to .y, for which RS applies only to China, Russia or Venezuela. A related controls note states that USML Category XIX(f)(1) does not control the commodities described in 9B619.

6. Software and technology

ECCN 9D619 covers software for commodities in 9A619, 9B619 or 9C619 (ECCN 9D619). Paragraph .b of that entry reaches software for developing or producing listed engine parts, including front, turbine center and exhaust frames, and mechanical parts such as fuel metering units. It also covers software for digital engine controls and engine monitoring systems. STA paragraph (c)(1) may not be used for 9D619.b, and paragraph (c)(2) may not be used for any software in the entry. Software directly related to Category XIX articles is controlled in USML paragraph XIX(g).

ECCN 9E619 covers technology required for developing, producing, operating, installing, maintaining, repairing, overhauling or refurbishing those commodities and software (ECCN 9E619). Build-to-print technology for the items in paragraphs .b.1 through .b.10 is classified under 9E619.a. Paragraph .c covers technology for listed parts such as blades, vanes, spools, shrouds, blisks, shafts and disks, and for digital engine controls and engine monitoring systems. STA paragraph (c)(1) may not be used for 9E619.b or .c. Software in 9D619.b and technology in 9E619.b and .c are not eligible for license exceptions except GOV under section 740.11(b)(2) (15 CFR 740.2(a)(13)). Engines that stay on the Munitions List are described in USML Category XIX: gas turbine engines.

Key terms

Military gas turbine engine	An engine specially designed for military end items in USML VI to VIII or ECCNs 0A606, 8A609 or 9A610.
Hot section components	Combustion chambers, liners and cooled turbine parts in 9A619.c.
Engine monitoring system	Equipment for prognostics, diagnostics and health monitoring.
ECCN 9A619.y	Specific listed engine parts such as oil lines, shims and nameplates.
USML XIX(g)	The Munitions List paragraph for Category XIX software and technical data.

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