CJ-05Edition 1.0 · November 2026
“Specially Designed” Decoded
Catch and release under the ITAR and the EAR
A step-by-step method for non-US companies to apply the ITAR and EAR definitions — catch first, then release — without mixing the two, and to keep the evidence each release needs.
What this guide settles
- Only analyse “specially designed” where the paragraph uses it — catch in (a) first, then releases in (b)
- One definition per regime: §120.41 for the USML, §772.1 for the CCL; a result never carries across
- Every release has elements, and every element needs evidence
- “Used in a defense article” starts the analysis; the releases decide
What you get
- The guide: explanations, method, conditions and limits
- Worked examples: questions to ask the supplier, a commented real case and ten pitfalls
- Tools printed in the guide: four templates and a readiness check
- Sources with section references and their verification date
- Revisions included for 12 months
Printed tools: T1 · Trigger and facts sheet · T2 · Catch-and-release worksheet · T3 · Release evidence log · T4 · Determination record and change log · Readiness check
Contents
- Before you start: scope and limits
- Why two words decide
- The rule in one page
- The words that decide
- The method in six steps
- Templates T1 to T4
- Ten pitfalls
- Case study: a release that was never earned
- Readiness check
What it does not cover
- Whether the item is on the USML at all, including enumerated paragraphs
- “600 series” and 9x515 items in depth, including .y paragraphs
- A formal determination: commodity jurisdiction request or BIS classification
Assumed knowledge. Finding the candidate USML paragraph or ECCN, the order of review (USML first, then CCL), and the item’s function and development history, or who holds them.
Sample pages





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Where it connects
Reading the USML
Reading the USML finds the candidate paragraph; “Specially Designed” Decoded tests the catch-all term inside it.
CJ-04Finding the Right ECCN
Finding the Right ECCN searches the CCL; “Specially Designed” Decoded applies the EAR definition where an entry uses it.
EAR-05600 Series & 9x515
“Specially Designed” Decoded runs the catch-and-release test; 600 Series & 9x515 uses it on every .x paragraph.
Part of a collection
“Specially Designed” Decoded is one of the eight guides of Classification & Jurisdiction (Understand the Rules), available together at €390 instead of €89 each.