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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).

Previous If an item subject to the EAR has been legally shipped to a VEU-eligible country, can it be transferred under authorization VEU within that country to a different eligible destination?
Next If I believe the “part,” “component,” “accessory,” “attachment,” or “software” I am classifying is likely ‘released’ under paragraph (b) because it likely meets the criteria of one of the paragraph (b) ‘releases,’ is it acceptable to skip paragraph (a) and proceed immediately to reviewing paragraph (b) first?
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