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If I am reviewing “specially designed” for a “part,” “component,” “accessory,” “attachment” or “software” in a catch-all paragraph, such as 9A610.x, can I review paragraph (a)(2) first instead of reviewing paragraph (a)(1)?



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  • If I am reviewing “specially designed” for a “part,” “component,” “accessory,” “attachment” or “software” in a catch-all paragraph, such as 9A610.x, can I review paragraph (a)(2) first instead of reviewing paragraph (a)(1)?
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Yes. This is a good time saving shortcut. For catch-all paragraphs, such as ECCN 9A610.x or any other paragraph that uses “specially designed” that controls unspecified “parts,” “components,” “accessories,” “attachments” or “software,” skipping paragraph (a)(1) and proceeding directly to (a)(2) is the best approach to save time. Remember, for “parts,” “components,” “accessories,” “attachments,” “software,” if ‘caught’ under (a)(1) or (a)(2) it is “specially designed,” unless ‘released’ from “specially designed” under paragraph (b).

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