How the 600 series fits the Commerce Control List

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1. Munitions entries on a dual-use list

The Export Administration Regulations (EAR) define the “600 series” as the Export Control Classification Numbers (ECCNs) in the “xY6zz” format on the Commerce Control List (CCL) (15 CFR 772.1). These entries cover items previously controlled on the U.S. Munitions List (USML) or covered by the Wassenaar Arrangement Munitions List (WAML). The “6” indicates that the entry is a munitions entry on the CCL. The “x” represents the CCL category and the “Y” the product group. The regulation sums it up by stating that the 600 series constitutes the munitions ECCNs within the larger CCL.

The Bureau of Industry and Security (BIS) maintains the CCL, which includes items, meaning commodities, software and technology (15 CFR 774.1(a)). An item is defined the same way in the definitions section (15 CFR 772.1). An ECCN consists of a set of digits and a letter.

2. How an entry is read

Terms on the CCL in double quotes are defined in part 772 of the EAR (15 CFR 774.1(d)(1)). Single quotes identify a term as defined in the context of a particular ECCN (15 CFR 774.1(d)(2)). The regulation describes reviewing the Related Definitions paragraph, and the Notes and Technical Notes, as a useful compliance practice to see whether a term is defined for a particular entry (15 CFR 774.1(d)).

The same numbering runs across the product groups. Entry 9A610 covers military aircraft and related commodities (ECCN 9A610). Entry 9D610 covers software specially designed for the development, production, operation or maintenance of military aircraft (ECCN 9D610). Entry 9E610 covers technology required across the life of military aircraft, from development and production through operation, installation, maintenance, repair, overhaul or refurbishing (ECCN 9E610).

3. The lettered paragraphs

The regulation itself refers to the specific paragraphs of a 600 series entry as paragraphs .a through .x (15 CFR 734.4(a)(6)(i)). The .x paragraph of an entry controls parts, components, accessories and attachments specially designed for its commodities. In ECCN 0A606, for example, .x reaches those items when specially designed for a commodity in the entry other than 0A606.b or .y, or for a defense article in USML Category VII, and not elsewhere specified (ECCN 0A606.x). The definitions section calls paragraph 9A610.x a catch-all, because it controls parts and similar items specially designed for military aircraft without naming specific types (15 CFR 772.1).

The .y paragraph lists specific parts, components, accessories and attachments specially designed for a commodity in the entry (ECCN 0A606.y). In ECCN 9A610 the paragraph also reaches parts and similar items specially designed for the listed .y items (ECCN 9A610.y). In ECCN 3A611, the .y list applies to parts specially designed for a commodity in any 600 series ECCN or for a defense article (ECCN 3A611.y).

4. Reasons for control

The 600 series items are controlled for national security (NS) reasons (15 CFR 742.4(a)). ECCN 0A606, for ground vehicles, lists NS, regional stability (RS), anti-terrorism (AT) and United Nations (UN) controls (ECCN 0A606). ECCN 9A610, for military aircraft, adds missile technology (MT) controls (ECCN 9A610). In that entry, paragraphs .t through .w carry MT controls, as do unmanned aerial vehicles and remotely piloted vehicles in .a capable of a range of at least 300 kilometers, regardless of payload.

Within an entry, controls can differ by paragraph. In ECCN 0A606, NS Column 1 applies to the entire entry except 0A606.b and .y, and 0A606.b is controlled at NS Column 2 (ECCN 0A606). RS Column 1 likewise applies except to .b and .y, and .b is at RS Column 2. UN controls apply to the entire entry except .y. In ECCN 9A610, NS and RS do not apply to the L-100 aircraft in 9A610.b, or to 9A610.x parts and components exported for use in those aircraft (ECCN 9A610).

Each entry also has a list based license exceptions section. ECCN 0A606 shows Shipments of Limited Value (LVS) up to $1,500 and no Shipments to Country Group B countries (GBS) (ECCN 0A606). ECCN 0A602, for guns and armament, allows LVS only up to $500 (ECCN 0A602). Software entries such as 9D610 show Technology and Software under Restriction (TSR) as not available (ECCN 9D610).

5. What the columns mean

The NS Column 1 license requirement reaches every destination but Australia, Canada and the United Kingdom (15 CFR 742.4(a)(1)). Country Group A:1 destinations are the only ones outside the NS Column 2 requirement (15 CFR 742.4(a)(2)). RS Column 1 exempts the same three countries (15 CFR 742.6(a)(1)).

For .y items, the regional stability control works differently. A .y item needs an RS license only when bound for China, Russia or Venezuela (15 CFR 742.6(a)(7)). Russia-bound items for the International Space Station are excepted. The ECCN tables mark this by listing RS for the .y paragraph against China, Russia or Venezuela (ECCN 0A606).

6. Military commodities and major defense equipment

When foreign-made military commodities contain more than de minimis U.S.-origin 600 series content, the related controls notes point to ECCN 0A919 (ECCN 0A606). The defined term “military commodity” does not include software, technology, items in ECCNs ending in 018, or any item in the 600 series itself (15 CFR 772.1).

The EAR also define 600 Series Major Defense Equipment (15 CFR 772.1). The term covers certain end items in ECCNs 9A610 and 9A619 whose research and development costs that do not recur exceed $50,000,000, or whose total production costs exceed $200,000,000. That definition feeds the contract value limits on license exceptions (15 CFR 740.2(a)(15)), covered in license exceptions for 600 series items. The way items fall into an entry is covered in specially designed and the catch-all paragraphs.

Key terms

600 series	The munitions ECCNs on the Commerce Control List, in the xY6zz format.
Paragraph .x	The parts and components paragraph of a 600 series entry.
Paragraph .y	A list of specific parts and components named in the entry.
NS Column 1	A license requirement to all destinations except Australia, Canada and the United Kingdom.
ECCN 0A919	The entry for foreign-made military commodities with more than de minimis 600 series content.

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

Equipment supporting programs abroad often moves under 600 series entries. 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.