9A610.a

2025-01-15

ECCN 9A610.a controls military aircraft and unmanned aerial vehicles (UAVs) that have been transitioned from the USML to the CCL. An export license is required to all destinations except Country Group A:1 allies under 15 CFR § 774, Supp. 1.

Category 9 — Aerospace and Propulsion — A. Systems, Equipment and Components

Reasons for Control

NS1NS2RS1RS2AT1UN

Regulatory Citation

15 CFR § 774, Supp. 1, ECCN 9A610

Licensing Policy

License required for all destinations for NS, RS reasons except Country Group A:1 (Wassenaar Arrangement participants). 600-series items receive heightened scrutiny. Presumption of denial for D:5, E:1, E:2. STA eligibility limited to § 740.20(c)(1) destinations with additional end-use certification requirements.

Controlled Technical Parameters

Technical Parameters

Parameter Name	Controlled Threshold	Unit	Regulatory Note
Military Specification Design	Specially designed	—	'Specially designed' is defined in § 772.1 using a multi-factor catch-and-release test. Items with both military and commercial applications must be evaluated against all six 'release' criteria.
Maximum Takeoff Weight (UAVs)	Varies by sub-item	kg	Certain lower-tier UAVs below MTCR Category I thresholds (500 kg payload, 300 km range) were transferred from the USML to the CCL under 9A610.
USML Transition Status	Not enumerated in USML Cat. VIII	—	Items that remain on the USML (e.g., F-35, MQ-9 Reaper) are controlled by DDTC under ITAR, not by BIS under the EAR. 9A610 only captures items that were affirmatively moved to the CCL during ECR.

Interactive License Determination Sandbox

AWAITING DESTINATION

Select a destination country above to perform a real-time export license determination against ECCN 9A610.

License Exception Matrix

License Exceptions Matrix

Exception Code	Full Name	Key Conditions	CFR Reference
STA	Strategic Trade Authorization	Available only to the 36 countries in § 740.20(c)(1) and only with a written statement from the consignee certifying end-use and no re-transfer per § 740.20(d)(1). Not available for 9A610.a items to Country Group D:5.	15 CFR § 740.20
GOV	Governments and International Organizations	Available for exports to agencies of cooperating governments and NATO per § 740.11(b). Requires government-to-government end-use certificate.	15 CFR § 740.11
TMP	Temporary Imports, Exports, and Reexports	Available for temporary exports for demonstration, exhibition, or evaluation subject to return within 12 months.	15 CFR § 740.9

Enforcement Case Studies

BIS Order — Bayraktar Supply Chain Investigation

1/21/2024Three U.S. Parts Suppliers (Names Sealed)Temporary Denial Orders; $1.2M Aggregate Civil Penalties

BIS investigation revealed three U.S. companies supplied 9A610-controlled military-specification avionics and sensor components to intermediaries that diverted them for integration into Bayraktar-class military UAV platforms being supplied to conflict zones without required licenses or end-use monitoring.

View Official Record

United States v. Syed Zain ul Abidin

11/13/2023Syed Zain ul Abidin78 Months Imprisonment; $250,000 Fine

Pakistani national convicted of conspiring to illegally export military-grade UAV components and ground control systems controlled under ECCN 9A610 from the U.S. to Pakistan's missile program, using fraudulent end-user certificates claiming civilian agricultural drone use.

View Official Record

Frequently Asked Questions

What is the difference between ECCN 9A610 and USML Category VIII?

USML Category VIII (controlled by the State Department / DDTC under ITAR) covers the most significant military aircraft, including fighter jets, attack helicopters, strategic bombers, and major military UAVs like the MQ-9 Reaper. ECCN 9A610 (controlled by the Commerce Department / BIS under the EAR) covers military aircraft and UAVs that were deemed less significant and were transferred to the Commerce Control List during the Export Control Reform (ECR) initiative. Items on the CCL under 600-series ECCNs generally have more flexible licensing procedures than ITAR-controlled items, including access to License Exception STA for allied destinations.

How do I determine if my UAV is controlled under 9A610 or is EAR99?

The key question is whether the UAV is 'specially designed' for military use as defined in § 772.1. This definition uses a 'catch and release' approach: an item is initially 'caught' if it has properties identified in § 772.1(a), and then may be 'released' from the definition if it meets any of the six criteria in § 772.1(b) — such as having equal or better performance than a commercial counterpart. A commercial agricultural drone with no military-specific hardening, no military-specification electronics, and no design for weapon delivery would typically be released from the 'specially designed' definition and classified as EAR99.

Can I export 9A610 items to NATO allies without a license?

Most NATO members are in Country Group A:1 (Wassenaar Arrangement participants), and ECCN 9A610 items are generally NLR (No License Required) to A:1 destinations for NS and RS reasons. Additionally, License Exception STA may be available for the 36 countries listed in § 740.20(c)(1). However, some NATO members may be subject to specific end-user restrictions, and a government-to-government end-use certificate may be required for certain 600-series items. Always verify the specific country's eligibility and check for Entity List or end-use restrictions under Part 744.

Does 9A610 cover UAV software and technology?

No. Software for 9A610 items is classified under ECCN 9D610, and technology for 9A610 items is classified under ECCN 9E610. These companion ECCNs have similar destination-based controls but different license exception eligibility. Notably, 'deemed exports' of 9E610 technology to foreign national employees within the U.S. require a license if the foreign national's country of citizenship would require a license for the technology.

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Regulatory Disclaimer

REGULATORY DISCLAIMER: This tool provides informational guidance only and does not constitute legal advice. Consult the Bureau of Industry and Security (BIS) or qualified export-control counsel for binding classification determinations. 15 CFR § 774; 50 U.S.C. § 4801 et seq.