Comment: One commenter stated that proposed ECCN 3A611.e duplicates equipment proposed to be classified under Category XI(a)(2)(v) and (vi). The commenter urged the Departments of State and Commerce to specify exactly what is proposed for each list either by name or discrete technical parameters.
Response: BIS believes that the commenter was referring to proposed Category XI(a)(3)(v) and (vi), which address radars, as does ECCN 3A611.e. (
Comment: Several commenters addressed the originally proposed ECCN 3A611.f, which applied to microelectronic devices or printed circuit boards produced at a trusted foundry, trusted source or trusted supplier accredited by the Defense Microelectronics Activity (DEMA). One commenter stated that this paragraph would be a positive move that would clearly define the articles covered. Other commenters perceived problems with the paragraph. Those perceived problems were: the paragraph appeared to be a delegation by BIS of a
Response: Upon review, the
Comments: One commenter stated that the .x concept in the 600 series is confusing and would frustrate users attempting to classify parts correctly. This commenter also stated that the .x control did not clearly align jurisdictional status of software and technology with the items to which they relate. This commenter suggested that confusion could be reduced by revising the first two related control notes in ECCN 3A611 to read, "(1) Electronic items that are BY THEMSELVES enumerated . . . ." and "(2) Electronic items `specially designed' for military end us that are not BY THEMSELVES controlled within any USML category but are within the scope of another `600 series' ECCN . . . ."
Another commenter stated that 3A611.x includes parts, components, accessories and attachments "specially designed" for military end use that are neither enumerated in any USML category nor another "600 series" ECCN. The commenter stated that it is not clear that there are any such parts, components, accessories and attachments. The commenter noted that electronics are often found in other end-items, and as such would be controlled under the ECCN for the end-item, and that the proposed language is not required and needlessly complicates the CCL.
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