Contingent upon your industry, you might have heard of 600 series Export Control Characterization Numbers (ECCNs). The 600 series incorporates things that were recently recorded in the US Weapons Rundown (USML) and constrained by the U.S. State Division per the Worldwide Traffic in Arms Guidelines (ITAR), or were covered by the Wassenaar Course of action Weapons Rundown (WAML). All things being equal, these things presently have been moved to the Business Control Rundown (CCL), directed by the U.S. Trade Division under the Export Organization Guidelines (EAR).
The initial 600 series ECCNs became real in 2013. However the 600 series has existed for very nearly 10 years, many are as yet scratching their heads considering what’s really going on with it.
Distinguishing a 600 Series ECCN
The term 600 series alludes to ECCNs that remember 6 as the third-from-last digit for the code. The codes take the configuration of xY6zz, where x addresses the CCL classification (0-9), Y Screen get of 5A611, a 600 series ECCN | Shipping Solutions Represents the CCL item bunch (A-E), and as a rule, the zz addresses the WAML classification.
Reason for 600 Series ECCNs
As a rule, controls identified with things on the USML are stricter than controls set on things on the CCL. This bodes well on the grounds that the USML is for things that have an expressly military-or guard related use Cargo sanctions Screening Solutions (higher danger), though the CCL is for double use things, which means things that have a business utilize yet can possibly be consolidated into a military-or safeguard related use (moderately lower hazard).
State and Business Division authorities made the assurance that a few things that recently showed up on the USML were preferred controlled under EAR over ITAR, and they marked these with the new 600 series ECCNs. Authorities moved these things to the EAR, to some degree, to slacken limitations to make it simpler to export these things to NATO nations and different partners. This isn’t to imply that that 600 series ECCNs get a free pass—a long way from it. Indeed, 600 series ECCNs will in general have stricter prerequisites than non-600 series ECCNs.
600 Series Export Compliance Prerequisites
As a rule, 600 series ECCNs are dependent upon the accompanying Business Nation Outline purposes behind control:
- Public safety Segment 1 (NS1)
- Provincial Strength Segment 1 (RS1)
- Hostile to Psychological oppression Segment 1 (AT1)
- Joined Countries ban (UN)
All things controlled for NS1 reasons, and most things controlled for RS1 reasons, necessitate that an exporter acquire a permit prior to exporting a 600 series thing to any country other than Canada. (For an outline of purposes behind control, see my past article Export Organization Guidelines: Understanding Explanations behind Control.)
All exports of 600 series things require an Electronic Export Data (EEI) recording through the Computerized Export Framework (AES), paying little heed to esteem or objective.
600 series things may not be exported to nations subject to U.S. arms bans.
Considered Exports of 600 Series ECCNs
A considered export happens when a U.S. organization discharges information on controlled innovation to an unfamiliar public. In contrast to exports of actual products, a considered export addresses the transmission of data itself.
Use innovation alludes to explicit data important for the utilization of an item dependent upon an innovation related ECCN.
Concerning exports of 600 series things, a permit is needed for considered exports of Utilization innovation when the accompanying conditions are met:
Innovation relating to at least one of the components of Utilization recorded in a 600 series ECCN will be delivered;
- The innovation isn’t freely accessible;
- The person to whom it is delivered is an outside public; AND
- A permit is needed to export the Utilization innovation to the singular’s nation of origin.
- 9×515 ECCNs
A different, however related gathering is 9×515 ECCNs. Instances of 9×515 ECCNs include: 9A515, 9B515, 9D515, 9E515. The 9×515 ECCNs depict rocket, related things and some radiation-solidified microelectronic circuits that were once dependent upon the ITAR under USML Classification XV.
All innovation related ECCNs use and language except for 600 series ECCNs and 9×515 ECCNs, which use or For instance, 9E915 (a 9×515 ECCN) peruses as follows:
Innovation needed for the advancement, creation, activity, establishment, fix, redesign, or restoring of shuttle and related products, as follows (see Rundown of Things Controlled).
Beside these two gatherings, innovation ECCNs use and rather than or. Accordingly 600 series and 9×515 innovation ECCNs are more extensive in scope than other innovation ECCNs, including a much more extensive scope of advancements. What’s more, very much like 600 series ECCNs, exporters should keep up with oversight on considered exports of 9×515 innovation.
The way to ensure your items are arranged appropriately and your compliance program is stayed up with the latest is to reference the pertinent guidelines. Peruse the text of the guidelines for each 600 series ECCN that is on your list of items for Export Control Compliance. Apparatuses like the Shipping Arrangements Item Characterization Wizard can assist with smoothing out the interaction.