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9x515 and 600 Series ECCNs

It’s important to note that there are two categories of ECCNs that trump other ECCNs: they are the 9x515 and 600 series.

The “600 series” describes military items that were once subject to the ITAR.

The 9x515 ECCNs describe “spacecraft,” related items, and some radiation-hardened microelectronic circuits that were once subject to the ITAR under USML Category XV.

Just as the ITAR effectively trumps the EAR, items described in a 9x515 ECCN or “600 series” ECCN trump other ECCNs on the CCL.

(See Supplement No. 4 to Part 774 of the EAR)

Example of 9x515 ECCNs are: 9A515, 9B515, 9D515, 9E515.

Note that export controlled “technology” has a broader definition than for other ECCNs:

“Technology” “required” for the “development,” “production,” operation, installation, repair, overhaul, or refurbishing of “spacecraft” and related commodities, as follows (see List of Items Controlled).

(ECCN 9E515 uses the word ‘or’, as opposed to ‘and’ which is used in other ECCNs for “use” “technology”)

Example 600 series ECCNs are: 1A607, 3B611, 6E619 Note that export controlled “technology” under 600 series ECCNs have a broader definition than for other ECCNS. For example, controls “Technology” “required” for the “development”, “production”, operation, installation, maintenance, repair, overhaul, or refurbishing of commodities controlled by 8A609, 8B609, or 8C609, or “software” controlled by 8D609 (see List of Items Controlled).

(Note that uses the word ‘or’, as opposed to ‘and’ which is used in other ECCNs for “use” “technology”).

Please contact the University's Export Control Officer if you are aware that the University will receive a 9x515 or 600 series, since we may need to implement a Technology Control Plan (TCP).