Jurisdiction

Export Control Reform: How Military Items Moved to the 600 Series

Export Control Reform, launched in 2009, moved thousands of military items from the USML to the CCL's 600 series and 9x515 entries. What moved, when and why.

Mar 18, 2026 Updated Oct 23, 2026 4 min read By ECCN.help

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

WhenWhat moved
15 October 2013First transitions: aircraft (USML VIII) and gas turbine engine (XIX) items to 9x610 and 9x619
2014Further categories, including vessels, vehicles, military electronics and spacecraft (USML XV to 9x515)
2020Firearms 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.

Frequently asked questions

What was Export Control Reform?

It was a U.S. government initiative, begun in 2009, that moved many less sensitive military items from the ITAR's U.S. Munitions List to the EAR's Commerce Control List, into new 600 series and 9x515 entries.

When did items start moving to the 600 series?

The first transitions took effect on 15 October 2013, starting with aircraft and gas turbine engine items. Other categories followed over the next years, including spacecraft to 9x515 in 2014 and firearms to 0x5zz entries in 2020.

Did every military item move off the USML?

No. The most sensitive items, for example many weapons, classified items and specific systems, remain on the USML.

Are 600 series items less controlled than ITAR items?

Generally yes, but they are still tightly controlled. Most licence exceptions are limited, and they carry special restrictions for arms-embargoed destinations.

How do I know if my item moved?

Review the current USML first. If the item is not described there, check the 600 series and 9x515 entries in the Commerce Control List before the rest of the list.

Related guides

← All export control guides · How to use ECCN.help