The 600 Series is Coming!
Article Summary
The 600 Series is a category on the Commerce Control List (CCL) created during Export Control Reform to manage items previously listed on the U.S. Munitions List (USML).
It was introduced to streamline export controls, improve licensing efficiency, and align U.S. regulations with international agreements like the Wassenaar Arrangement.
The 600 Series includes military items, such as parts, components, and equipment, that were formerly controlled under the USML but are now subject to dual-use export controls.
Items in the 600 Series may require a license for export, depending on the destination, end-user, and end-use, but the process is generally less restrictive than under the USML.
The "6" indicates that the item is a munitions-related entry, distinguishing it from other categories on the CCL.
Exporters should classify items correctly, screen end-users, and review licensing requirements under the Export Administration Regulations (EAR).
Introduction: Major reforms are officially under way in the United States export control system. Many items that were considered Military in nature, and thus subject to stringent controls, will soon be re-classified. The aim of the reform is to move less significant Military items from State Department control to the Commerce Department where they will be subject to more liberal controls. These items, newly labelled as the ‘600’ series, could result in easier exporting for you! The details were announced today (April 15th, 2013) and the changes will take effect on October 15th, 2013.
What does this mean to me? If you produce goods or technologies that are currently on the US Military List, and are thus controlled by the International Traffic in Arms Regulations (ITAR), these changes will apply to you. Such items currently controlled under the ITAR will need to be reclassified. In addition to items moving to Commerce department control, the ITAR Categories are being re-written and you will need to ensure that you have the correct classification for your goods.
How can I classify my goods? By following the State and Commerce department websites, and the site set up specifically for Export Control Reform (http://export.gov/ecr/) you can read about the changes and their implementation. If you need assistance in re-classifying any of your goods, CTP Inc. has a team of experts who can assist you with this process.
What if my goods move to Commerce Department control under the 600 Series? This may be good news for you. Your items will still be under export control but will be listed under the Export Administration Regulations (EAR) rather than ITAR. The EAR has some relaxations that are not available under the ITAR and you may be able to export your goods under a license exception or other expedited processes. However, if you have always dealt with the State Department under ITAR, you will now need to understand the processes used by the Commerce department. Several CTP employees are former BIS experts, so we are familiar with the DOC system and can guide you through in the most effective way.
I have already exported goods to Europe. How can I deal with these? The extra-territorial nature of the ITAR controls means that goods sent abroad will still come under ITAR controls for re-transfer. It is important that these goods are also re-classified as it may mean that these controls can be relaxed. The pending changes to the U.S. legislation will have an impact worldwide and it is important that U.S. exporters or multinationals quickly re-assess their inventories in third countries. Within Europe, CTP works with Interexport Management Systems Ltd (IMS) who are experts on classifications within the EU region. IMS will guide you through the ‘600’ series changes while also advising on existing EU legislation. Remember that a U.S. Military item that is moved to the ‘600’ series will still be considered as a Military item in most other countries in the world. IMS– with its experts in the UK, Germany, Holland and Estonia–can advise you on the classification of your goods under different legislation.
Where can I get more information? The State and Commerce departments are keeping U.S. Industry informed through their websites as these changes unfold. For more specific advice and services, call Rick Phipps to discuss your compliance situation.
Key Points
What is the 600 Series, and why was it created?
The 600 Series is a category on the Commerce Control List (CCL) established as part of the Export Control Reform (ECR) initiative. It was created to shift certain military items from the United States Munitions List (USML) to the CCL, making them subject to the Export Administration Regulations (EAR) instead of the more restrictive B'International Traffic in Arms Regulations (ITAR). This' change aims to:
- Streamline Export Controls: Simplify the licensing process for certain military items.
- Enhance Efficiency: Reduce regulatory burdens for exporters.
- Align with International Agreements: Ensure compliance with the Wassenaar Arrangement and other global frameworks.
What types of items are included in the 600 Series?
The 600 Series includes items that were previously controlled under the USML but are now subject to dual-use export controls. These items typically include:
- Military Parts and Components: Such as aircraft parts, vehicles, and protective equipment.
- Support Equipment: Items used in military operations but not classified as weapons.
- Former ECCNs Ending in -018: Items previously classified under specific Export Control Classification Numbers (ECCNs).
These items are still subject to strict controls but benefit from a more flexible licensing framework under the EAR.
How does the 600 Series impact export licensing requirements?
Export licensing for 600 Series items depends on several factors:
- Destination: Certain countries may require a license for export.
- End-User: Exporters must screen recipients to ensure they are not restricted parties.
- End-Use: Items intended for prohibited uses, such as military proliferation, may require additional scrutiny.
While the 600 Series simplifies licensing compared to the USML, exporters must still comply with EAR requirements to avoid violations.
What is the significance of the "6" in the 600 Series?
The "6" in the 600 Series indicates that the item is munitions-related. This designation helps distinguish these items from other categories on the CCL, such as:
- Dual-Use Items: Controlled under other ECCNs.
- Purely Commercial Items: Not subject to military-related controls.
The "6" serves as a clear identifier for items that require special attention due to their military applications.
How does the 600 Series align with international export control agreements?
The 600 Series aligns U.S. export controls with international agreements, such as the Wassenaar Arrangement, by:
- Harmonizing Regulations: Ensuring consistency with global standards.
- Reducing Redundancy: Avoiding overlap between U.S. and international controls.
- Facilitating Trade: Simplifying the export process for U.S. companies while maintaining national security.
This alignment strengthens global cooperation and ensures that U.S. export controls remain effective and relevant.
What steps should exporters take to ensure compliance with the 600 Series?
To comply with the 600 Series, exporters should:
- Classify Items Correctly: Determine the appropriate ECCN for each item.
- Screen End-Users: Verify that recipients are not on restricted party lists.
- Review Licensing Requirements: Check whether a license is needed based on the destination and end-use.
- Maintain Records: Keep detailed documentation of all export transactions for at least five years.
By following these steps, exporters can navigate the 600 Series requirements effectively and avoid penalties for non-compliance.
