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Paragraph (b)(6) looks similar to paragraph (b)(4) in its construction, so what is the purpose of paragraph (b)(6)?



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Paragraph (b)(6) is similar to paragraph (b)(4), but the paragraph (b)(6) ‘release’ is specific to AT-only ECCNs that use “specially designed.” Under the paragraph (b)(6) ‘release,’ if the “part,” “component,” “accessory,” “attachment,” or “software” was “developed” for use in or with AT-only ECCNs and also EAR99 commodities or software, it would not be “specially designed.” Or if the “part,” “component,” “accessory” was “developed” exclusively for EAR99 commodities or software, it would not be “specially designed.” Under both of these scenarios to be ‘released’ from “specially designed” you must have documentation from the “development” phase meeting the paragraph (b)(6) criteria.”

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