A 600 series ECCN is a Commerce Control List (CCL) entry whose three-digit number begins with 6, such as 0A606, 3A611 or 9A610. The 600 series holds military items that left the U.S. Munitions List (USML) under export control reform. To classify an item there, confirm it is not on the USML, find the matching entry, then check the enumerated paragraphs, the .y list and the "specially designed" test for .x, in that order. How the items got there is covered in how items moved from the USML to the 600 series; this guide is about classifying them today.
How to recognise a 600 series ECCN
The first digit of the three-digit number is 6. The main end-item entries are:
- 0A606, ground vehicles
- 1A613, armour and protective equipment
- 3A611, military electronics
- 8A609, surface vessels of war
- 9A610, military aircraft
- 9A619, military gas turbine engines
Each has matching B, C, D and E entries (9B610, 9D610, 9E610 and so on) for test equipment, materials, software and technology.
The paragraph structure: .a to .w, .x and .y
Paragraphs .a to .w cover end items and the specific systems, parts and components the entry enumerates.
Paragraph .x covers parts, components, accessories and attachments "specially designed" for the entry's items, or for USML items in the corresponding category, that are not enumerated on the USML or elsewhere in the entry. Read its wording closely: because it usually reaches parts for the corresponding USML category's items as well, a part for an ITAR end item can still be 600 series .x.
Paragraph .y lists specific lower-sensitivity items, for example certain lamps, filters, tyres or seals specially designed for military items, controlled mainly for anti-terrorism reasons. The list is short and specific. An item not listed there cannot be .y.
Also read the entry's Related Controls. They point back to the USML category, and items described there are ITAR items and outside the 600 series.
How to classify a 600 series item step by step
- Confirm it is not on the USML. If a USML paragraph enumerates it, it is ITAR. See the USML categories and ITAR vs. EAR.
- Find the matching 600 series entry for the end item's category. The EAR's Order of Review requires checking the 600 series before the general CCL.
- Check the enumerated paragraphs (.a to .w).
- Check .y. If the item is listed there, it is .y.
- Apply "specially designed". Caught and not released means .x. See the catch-and-release test.
- If the item is released, classify it elsewhere on the CCL, often in a 9xx entry, or as EAR99.
Worked examples
| Item | Reasoning | Result |
|---|---|---|
| Custom wiring harness built for one military helicopter model | Caught by "specially designed", not released | 9A610.x |
| Landing light specially designed for military aircraft | Listed in 9A610.y | 9A610.y |
| Standard fastener in the same aircraft | Released as a fastener | Not 600 series |
| Maintenance software specially designed for 9A610 aircraft | Software for the entry's items | 9D610 |
Licence requirements and licence exceptions
600 series items are typically controlled for national security (NS1), regional stability (RS1), anti-terrorism and UN reasons. The License Requirements section of each entry shows which paragraphs carry NS1, RS1, AT1 and UN, and which (typically .y) carry AT only. The codes are explained in reasons for control.
Because of the RS1 control, a licence is usually required for 600 series .a to .x items to all destinations except a short list of close allies. Licence exceptions are limited: some STA use for Country Group A:5, some GOV and TMP uses (see License Exceptions TMP, STA and GOV), and restrictions for arms-embargoed destinations (Country Group D:5). Those destinations also face a policy of denial for most items.
The .y items are controlled mainly for anti-terrorism reasons and are licensable much more widely. That difference is the reason to separate .x from .y carefully. Always read the entry's own License Requirements.
De minimis and foreign-made items
Foreign-made items that incorporate 600 series content face special de minimis rules: for some destinations, any 600 series content makes the foreign item subject to the EAR. If your products are built abroad with U.S. military-derived parts, include this in your review.
Common 600 series mistakes
- Jumping to the general CCL without checking the 600 series first.
- Treating .x as a catch-all without testing the releases.
- Overlooking .y, which is lighter than .x.
- Forgetting the de minimis rules for 600 series content in foreign-made items.
600 series in ECCN.help
The ECCN.help Classification Workflow follows the Order of Review, checking the 600 series and 9x515 before the rest of the CCL, and asks the "specially designed" catch and release questions one by one. It is rule-based, with no AI, and every answer is recorded.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.