This Guidance does not create any privileges, benefits, or rights, substantive or procedural, enforceable by any individual, organization, party, or witness in any administrative, civil, or criminal matter.



A.8: No, you would need to review the EAR "specially designed" definition to make such a determination. If the item is subject to the EAR and you are following the CCL Order of Review to make a determination whether an item is "specially designed," you must review the EAR "specially designed" definition and NOT the ITAR definition of "specially designed." This is very important to understand because in many cases an item that is not "specially designed" under the ITAR would be "specially designed" under the EAR, such as under a "600 series" .x paragraph. This same concept also applies for the review of "specially designed" under the "600 series" ECCNs and the rest of the CCL. The EAR "specially designed" definition is used for both "600 series" and other ECCNs on the CCL, but even if the item is not a "600 series" "specially designed" item, it still could be a "specially designed" item elsewhere on the CCL, if you are reviewing a paragraph that uses "specially designed."

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