Export Control Reform (ECR) was a U.S. government initiative, launched in 2009, that moved thousands of less sensitive military items from the ITAR's U.S. Munitions List (USML) to the EAR's Commerce Control List (CCL). It created the 600 series and the 9x515 entries. The first transitions took effect on 15 October 2013. Before that, a bolt made for a military aircraft was controlled much like the aircraft itself: under the ITAR, with a State Department licence needed for export to any country.
Why export control reform happened
By the late 2000s, the USML caught large numbers of generic parts and components along with genuinely sensitive defense articles. The result was licensing volume that slowed exports to close allies without improving security. ECR aimed at a "higher fence around fewer items". The most sensitive items would stay on the USML, and the rest would move to the EAR, where controls can be tailored by destination.
How the reform worked
The USML categories were rewritten as positive lists that enumerate specific items, in place of broad catch-alls. The current structure is summarised in the 21 USML categories.
A common "specially designed" definition, in both regulations, decided whether parts and components stay caught: § 120.41 in the ITAR and § 772.1 in the EAR (see the catch-and-release test).
Items leaving the USML went into new 600 series entries on the CCL, for example 9A610 for military aircraft items, 0A606 for ground vehicles and 3A611 for military electronics. Spacecraft items went into 9x515.
Export control reform timeline
| When | What moved |
|---|---|
| 15 October 2013 | First transitions: aircraft (USML VIII) and gas turbine engine (XIX) items to 9x610 and 9x619 |
| 2014 | Further categories, including vessels, vehicles, military electronics and spacecraft (USML XV to 9x515) |
| 2020 | Firearms and ammunition (USML I–III): many commercial firearms moved to new 0x5zz entries, for example 0A501 |
The Federal Register rules for each category record the changes, and the current USML and CCL are on the eCFR (the EAR, including the CCL, is at the eCFR EAR text).
Did every military item move?
No. The most sensitive items, for example many weapons, classified items and specific systems, remain on the USML.
What the 600 series looks like
A 600 series ECCN has a 6 as the first digit of its number: 0A606, 1A613, 9A610. Its paragraphs typically run from .a (end items or major systems) to .x (parts, components, accessories and attachments "specially designed" for them), with .y for specific lower-sensitivity parts controlled mainly for anti-terrorism reasons. How to classify 600 series items works through the paragraphs one by one.
Are 600 series items dual-use?
Not in the usual sense. They are military items subject to the EAR, with stricter controls than most dual-use entries. For the usual meaning of the term, see defense articles vs. dual-use items.
What export control reform means for exporters today
- The order of review is fixed. The EAR's Order of Review (Supplement No. 4 to Part 774) requires checking the USML first, then 600 series and 9x515 entries, before the rest of the CCL.
- Controls stay tight. 600 series items are subject to the EAR but carry national security and regional stability controls, limited licence exceptions (STA only in part) and a licence requirement for arms-embargoed destinations.
- Parts are often caught. Items "specially designed" for 600 series end items fall in their .x paragraphs even when they look generic.
- De minimis is different. Special de minimis rules apply to foreign-made items incorporating 600 series content.
A worked example
Take a machined bracket made to a military aircraft manufacturer's drawing for one aircraft model. After ECR it is no longer a USML item (unless specifically enumerated), so the next check is 9A610. It is a part "specially designed" for a military aircraft, and no release in the definition applies, so it is 9A610.x.
Had it been a standard catalogue bracket used across civil and military aircraft, the release for items with civil counterparts could have taken it out of the 600 series.
ECR and ECCN.help
The ECCN.help Classification Workflow follows the Order of Review: the ITAR vs. EAR check first, then 600 series and 9x515 entries before the rest of the list, with the "specially designed" test asked step by step. For the jurisdiction question itself, see ITAR vs. EAR.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.