ECCN 9A515

NSRSMTAT

Spacecraft and related commodities, as follows .

Category: 9 - AerospaceProduct Group: A - EquipmentLast Updated: 2026-04-10

What This ECCN Covers

ECCN 9A515 controls "spacecraft" and related commodities that are subject to the EAR — including certain satellites, space vehicles, sub-orbital craft, and specially designed parts and components that are not on the U.S. Munitions List. The Regional Stability reason reflects policy-based destination controls on space hardware, alongside National Security, Missile Technology, and Anti-Terrorism reasons.

Who needs to check this?

Commercial satellite and spacecraft manufacturers, component suppliers, and sub-orbital vehicle developers exporting EAR-controlled space hardware.

Compliance tip

Space hardware is split between the USML (ITAR) and 9A515/9A004 — determine jurisdiction first, since "specially designed" defense items may be ITAR-controlled. License Exception STA has special eligibility rules for 9x515 items; review §740.20 and the Regional Stability columns carefully before relying on any exception.

Reviewed by Jack Tan · Last reviewed: Jun 4, 2026

Items Covered

  • a."Spacecraft," including satellites, and space vehicles and "sub-orbital craft," whether designated developmental, experimental, research or scientific, not described in USML Category XV or described in ECCN 9A004.r, .u, or .w, that:
  • 1. Have electro-optical remote sensing capabilities and having a clear aperture greater than 0.35 meters, but less than or equal to 0.50 meters;
  • 2. Have remote sensing capabilities beyond NIR (i.e., SWIR, MWIR, or LWIR);
  • 3. Have radar remote sensing capabilities (e.g., AESA, SAR, or ISAR) having a center frequency equal to or greater than 1.0 GHz, but less than 10.0 GHz and having a bandwidth equal to or greater than 100 MHz, but less than 300 MHz;
  • 4. Provide space-based logistics, assembly, or servicing of another "spacecraft"; or
  • 5. Are not described in ECCN 9A515.a.1, .a.2, .a.3 or .a.4.
  • b.Equipment for telemetry, tracking, and control, as follows:
  • 1. Ground control systems and training simulators specially designed for telemetry, tracking, and control of the "spacecraft" controlled in paragraphs 9A004.u or 9A515.a;
  • 2. Terrestrial equipment specially designed for "spacecraft," as follows:
  • 2.a. Telemetry and telecommand equipment specially designed for any of the following data processing functions:
  • 2.a.1. Telemetry data processing of frame synchronization and error corrections, for monitoring of operational status (also known as health and safe status) of the "spacecraft bus;" or
  • 2.a.2. Command data processing for formatting command data being sent to the "spacecraft" to control the "spacecraft bus;"
  • 3. Simulators specially designed for 'verification of operational procedures' of "spacecraft."
  • d.Microelectronic circuits (e.g., integrated circuits, microcircuits, or MOSFETs) and discrete electronic components rated, certified, or otherwise specified or described as meeting or exceeding all the following characteristics and that are specially designed for defense articles, "600 series" items, or items controlled by ECCNs 9A004.v or 9A515:
  • 1. A total dose of 5 × 105 Rads (Si) (5 × 103 Gy (Si));
  • 2. A dose rate upset threshold of 5 × 108 Rads (Si)/sec (5 × 106 Gy (Si)/sec);
  • 3. A neutron dose of 1 × 1014 n/cm2 (1 MeV equivalent);
  • 4. An uncorrected single event upset sensitivity of 1 × 10−10 errors/bit/day or less, for the CRÈME-MC geosynchronous orbit, Solar Minimum Environment for heavy ion flux; and
  • 5. An uncorrected single event upset sensitivity of 1 × 10−10 errors/part or less for a fluence of 1 × 107 protons/cm2 for proton energy greater than 50 MeV.
  • e.Microelectronic circuits (e.g., integrated circuits, microcircuits, or MOSFETs) and discrete electronic components that are rated, certified, or otherwise specified or described as meeting or exceeding the characteristics in either paragraph e.1 or e.2, AND specially designed for defense articles described in USML Category XV or items controlled by ECCNs 9A004.u or 9A515:
  • 1. A total dose ≥1 × 105 Rads (Si) (1 × 103 Gy(Si)) and <5 × 105 Rads (Si) (5 × 103 Gy(Si)); and a single event effect (SEE) (i.e., single event latchup (SEL), single event burnout (SEB), or single event gate rupture (SEGR)) immunity to a linear energy transfer (LET) ≥80 MeV-cm2/mg; or
  • 2. A total dose ≥5 × 105 Rads (Si) (5 × 103 Gy (Si)) and not described in 9A515.d.
  • f.Pressure suits (i.e., space suits) capable of operating at altitudes greater than or equal to 55,000 feet above sea level.
  • g.Remote sensing components specially designed for "spacecraft" described in ECCNs 9A515.a.1 through .a.4 as follows:
  • 1. Space-qualified optics (i.e., lens, mirror, membrane having active properties (e.g., adaptive, deformable)) with the largest lateral clear aperture dimension equal to or less than 0.35 meters; or with the largest clear aperture dimension greater than 0.35 meters but less than or equal to 0.50 meters;
  • 2. Optical bench assemblies specially designed for ECCN 9A515.a.1, a.2, a.3, or a.4 "spacecraft;" or
  • 3. Primary, secondary, or hosted payloads that perform a function of ECCN 9A515.a.1, a.2, a.3, or a.4 "spacecraft."
  • h.Spacecraft thrusters using bi-propellants or mono-propellants that provide thrust equal to or less than 150 lbf (i.e., 667.23 N) vacuum thrust.
  • w."Parts," "components," "accessories," and "attachments" that would otherwise be within the scope of ECCN 9A515.x but that have been identified by the interagency as warranting control in 9A515.w, as follows:
  • x."Parts," "components," "accessories" and "attachments" that are specially designed for defense articles described in USML Category XV or items controlled by 9A515, and that are NOT:
  • 1. Described on the USML or elsewhere within ECCNs 9A515 or 9A004;
  • 2. Microelectronic circuits and discrete electronic components;
  • 3. Described in ECCNs 7A004 or 7A104;
  • 4. Described in an ECCN containing "space-qualified" as a control criterion (i.e., 3A001.b.1, .e.4 or .z, 3A002.g.1, 3A991.o, 3A992.b.3, 6A002.a.1, .b.2, .d.1, 6A004.c and .d, 6A008.j.1, 6A998.b, or 7A003.d.2);
  • 5. Microwave solid state amplifiers and microwave assemblies (refer to ECCN 3A001.b.4 and .z for controls on these items);
  • 6. Travelling wave tube amplifiers (refer to ECCN 3A001.b.8 and .z for controls on these items); or
  • 7. Elsewhere specified in ECCN 9A515.y.
  • y.Items that would otherwise be within the scope of ECCN 9A515.x but that have been identified in an interagency-cleared commodity classification (CCATS) pursuant to § 748.3(e) as warranting control in 9A515.y.
  • 1. Discrete electronic components not specified in 9A515.e;
  • 2. Thermistors for spacecraft applications;
  • 3. RF microwave bandpass ceramic filters (e.g., Dielectric Resonator Bandpass Filters);
  • 4. Hall effect sensors for spacecraft applications;
  • 5. Subminiature (SMA and SMP) plugs and connectors, TNC plugs and cable and connector assemblies with SMA plugs and connectors for spacecraft applications;
  • 6. Flight cable assemblies for spacecraft applications;
  • 7. Public address (PA) systems;
  • 8. Audio selector panels;
  • 9. Spacecraft crew, passenger, or participant lavatories and body waste management systems;
  • 10. Spacecraft crew, passenger, or participant hygiene facilities and systems;
  • 11. Spacecraft crew, passenger, or participant crew rest equipment or sleeping quarters;
  • 12. Spacecraft crew, passenger, or participant galleys or food preparation or serving systems;
  • 13. Spacecraft crew, passenger, or participant entertainment systems;
  • 14. Spacecraft crew, passenger, or participant exercise systems;
  • 15. Spacecraft crew, passenger, or participant laundry systems;
  • 16. Spacecraft crew, passenger, or participant safety systems, not including launch abort systems/launch escape systems, ejector seats, spacesuits, flight suits, helmets, or "parts" and "components" therefor;
  • 17. Spacecraft crew, passenger, or participant storage units, facilities, or systems (for items related to human safety, welfare, and health);
  • 18. Spacecraft crew, passenger, or participant medical facilities or health-related systems for monitoring, evaluating, or assessing, or for providing treatments;
  • 19. Spacecraft crew, passenger, or participant information systems (e.g., personal laptops and phones);
  • 20. Name plates, identification plates, and identification systems;
  • 21. Internal, external, and emergency lighting systems;
  • 22. Humidity and CO2 removal systems;
  • 23. Potable water storage systems;
  • 24. Water regeneration systems;
  • 25. Air filters, filter networks, or air quality systems;
  • 26. Space heaters, temperature sensors, or thermostats for human habitation;
  • 27. Environmental control systems for human habitation;
  • 28. Spacecraft environmental control systems (e.g., air conditioner, air distribution, air filtration and sanitation, CO2 removal, cabin pressure control, dehumidifier, fire suppression system, nitrogen oxygen recharge system, heater systems, thermostats);
  • 29. Plant growth systems;
  • 30. Fire extinguishers;
  • 31. Flame, smoke, or CO2 detectors;
  • 32. Fire suppression systems;
  • 33. Spacecraft crew, passenger, or participant seats, other than ejection seats, and "parts" and "components;"
  • 34. Spaceflight crew, passenger, or participant ejection seat mounted survival aids;
  • 35. Spaceflight crew, passenger, or participant life rafts;
  • 36. Spacecraft crew, passenger, or participant locator beacons;
  • 37. Spacecraft crew, passenger, or participant mirrors;
  • 38. Spacecraft crew, passenger, or participant windows;
  • 39. Spacecraft locator beacons;
  • 40. Viewing windows on non-crewed spacecraft;
  • 41. Temperature sensors and pressure transducers;
  • 42. Thermal control pumps, accumulators, fluid filters and filter assemblies, control valves, heat exchangers, and radiators;
  • 43. Hydraulic, pneumatic, oil, fuel, gas, propellant, fluid, and thermal control fluid reservoirs, filters, filter assemblies, tubing, lines, hoses, check valves, and quick disconnects, and associated fittings, couplings, clamps, brackets, adapters, valves, gaskets, shims, and o-rings;
  • 44. Gauges and indicators;
  • 45. Filtered and unfiltered panel knobs, indicators, annunciator panels, switches, buttons and dials;
  • 46. Spacecraft tires and brake systems (does not include sintered mix or carbon/carbon materials);
  • 47. Bearings (e.g., Ball, roller, wheel);
  • 48. Energy dissipating pads for cargo or crew;
  • 49. Spacecraft bus structures;
  • 50. Bracket adapters for bus and payload structures;
  • 51. Latches and hinges;
  • 52. Boom assemblies;
  • 53. Cables, cable assemblies, and connectors;
  • 54. Batteries and associated battery management circuitry;
  • 55. Germanium coated polyimide tapes (e.g., Kapton tape);
  • 56. Multiplexors and Demultiplexors (MUX & DEMUX);
  • 57. Switches, switch bank assemblies, beam select switches, transfer switch assemblies, switch matrices, thermal switches;
  • 58. Magnetic torque bars;
  • 59. Filters, filter networks;
  • 60. Network switches;
  • 61. Reflectors, antennas;
  • 62. Antenna feed horns;
  • 63. Diplexers, modulators, demodulators;
  • 64. Second surface mirrors;
  • 65. Backshells, pins and contacts;
  • 66. Measurement devices;
  • 67. Electrical power distribution and control units;
  • 68. Electrical connectors;
  • 69. Non-propulsive landing systems (e.g., skids, inflatable);
  • 70. Electric fans;
  • 71. Microphones;
  • 72. Speakers;
  • 73. Circuit breakers; and
  • 74. Printed circuit boards specially designed for items classified under 9A515.y

4 items reserved by BIS (not shown)

Control Reasons

NSNational Security

Items controlled for national security reasons under multilateral export control regimes.

Column 1: YesColumn 2: No
RSRegional Stability

Items controlled for regional stability reasons.

Column 1: YesColumn 2: No
MTMissile Technology

Items controlled under the Missile Technology Control Regime (MTCR).

Column 1: YesColumn 2: No
ATAnti-Terrorism

Items controlled for anti-terrorism reasons. Most items on the CCL have AT controls.

Column 1: YesColumn 2: No

Disclaimer

This information is for reference only. For official classifications, consult BIS or a qualified export control professional.

Official Reference