Export Controls: How can we define ”modified for a military application”?

Question

How can we define ”modified for a military application”? Does any modification trigger a military control?

(This question was asked at one of our recent webinars on Export Controls. You can listen to this webinar on our recent webinars page at http://opentoexport.com/info/webinars/)

Answer

There is a Note under entry ML6 which reads ‘Note: In ML6.a. modification of a ground “vehicle” for military use entails a structural,
electrical or mechanical change involving one or more specially designed
military components.’ While this strictly only applies to ML6 items, it is a general interpretation for a modification for military use. Essentially, if the military has specified any change to a dual use item, it will normally be considered as modified for military use and controlled under the military list.

Answer

There is a Note under entry ML6 which reads ‘Note: In ML6.a. modification of a ground “vehicle” for military use entails a structural,
electrical or mechanical change involving one or more specially designed
military components.’ While this strictly only applies to ML6 items, it is a general interpretation for a modification for military use. Essentially, if the military has specified any change to a dual use item, it will normally be considered as modified for military use and controlled under the military list.

Answer

There is a Note under entry ML6 which reads ‘Note: In ML6.a. modification of a ground “vehicle” for military use entails a structural,
electrical or mechanical change involving one or more specially designed
military components.’ While this strictly only applies to ML6 items, it is a general interpretation for a modification for military use. Essentially, if the military has specified any change to a dual use item, it will normally be considered as modified for military use and controlled under the military list.

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