The 600 series and 9x515 Export Control Classification Numbers (ECCNs) play a critical role in the Commerce Control List (CCL) order of review and throughout the Export Administration Regulations (EAR). To understand why they take precedence, it’s important to first look at what they are and why they matter.
600 series ECCNs are those with a “6” in the third-to-last digit of the ECCN, following an “xY6zz” structure in which:
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x = CCL category
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y = CCL product group
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zz=Generally characterizes the Wassenaar Arrangement Munitions List (WAML) category
For example, an ECCN might look like 0A606, 3A611, 8A620, and others. Items in the 600 series are sensitive military commodities, and the “6” designates that the entry is a “munitions entry on the CCL". These items were previously controlled under the U.S. Munitions List (USML) or covered by the Wassenaar Arrangement Munitions List (WAML). Because of their military significance, 600 series items are given elevated priority and stricter control requirements within the EAR.
Now let’s look at the 9x515 ECCNs. These classifications cover spacecraft-related items and certain “radiation-hardened microelectronic circuits” that were previously controlled under the ITAR, specifically U.S. Munitions List (USML) Category XV. ECCNs in this group end in “515”, with the placeholder “x” indicating the applicable product group (A–E). Examples include 9A515, 9B515, and others within the series. Much like how ITAR controls take precedence over the EAR, the EAR’s own order of review gives priority to items classified under the 600 series and 9x515 ECCNs, meaning these categories trump other ECCNs on the CCL.
600 series and 9x515 in the order of review process
As noted earlier, these ECCNs play a significant role in the CCL as they appear in Steps 3 and 4 of the order of review process, outlined in Supplement No. 4 to Part 774. Once you identify your item’s product group in Step 2, the next step is to determine whether it is classified under a 600 series or 9x515 ECCN.
In Step 4, you must then assess whether your item is captured by a catch-all paragraph within a 9x515 or 600 series ECCN that uses the term “specially designed.” These catch-all provisions typically appear in the “.x” paragraphs of these ECCNs. If your item is potentially covered by one of these paragraphs, a detailed specially designed analysis must be conducted.
Consideration for 600 series and 9x515 ECCNs
Some key considerations for 600 series and 9x515 ECCNs include:
- ECCN disclosure requirement: The ECCN must be listed on the commercial invoice for 600 series and 9x515 items as part of the export clearance process.
- Stricter reasons for control: These ECCNs typically carry more stringent reasons for control—such as National Security (NS1), Regional Stability (RS1), and others—which often require a license.
- Filing EEI through the AES: Filing exemptions are not available and therefore you must file the Electronic Export Information (EEI) via the Automated Export System (AES) for 600 series and 9x515.a through .x items (excluding .y items). See §758.1 for specific requirements.
- Embargo restrictions: These items cannot be exported to embargoed destinations.
Conclusion
Both 600 series and 9x515 ECCNs are high-priority ECCNs under the EAR, and as such, they demand heightened attention throughout the export lifecycle—from initial classification to licensing, export clearance, etc. Given the sensitivity of these items, exporters should consistently apply rigorous due diligence and ensure full compliance with all regulatory requirements. As the regulations evolve, exporters should continuously review the Federal Register and BIS updates to ensure compliance with the latest requirements for these sensitive items.
Do you have questions about your organization’s export controls?
Visit www.learnexportcompliance.com to learn about our company, our faculty, our staff and our esteemed Export Compliance Professional (ECoP®) certification program. To find upcoming e-seminars, live seminars in the U.S., Europe, and elsewhere, live webinars and to browse our wide-ranging library of on-demand webinars, continuously updated with new topics, visit ECTI Academy. You can also contact the Export Compliance Training Institute at info@learnexportcompliance.com or by phone at 540-433-3977 for more information.
Maria G. Ferree is Export Controls Associate at ECTI.
