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How does “specially designed” fit into the larger review of the CCL, given “specially designed” is used in the “600 series,” as well as other ECCNs on the CCL?



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The Commerce Control List Order of Review in Supplement No. 4 to Part 774 was added to the EAR through the April 16, 2013 Initial Implementation of ECR final rule. The CCL Order of Review consists of six steps that guide you through how to analyze the CCL, starting with the “600 series” and then reviewing the other ECCNs on the CCL. The CCL Order of Review specifies when you need to analyze “specially designed” as part of the larger review of the CCL, both when reviewing the “600 series” and then, if needed, when reviewing other ECCNs on the CCL.

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