Export control for US aircraft parts: what a buyer outside the US should prepare
Most commercial aircraft parts made in the United States can be shipped to most countries without an export license. Orders that get stuck usually stall on a destination, end user or end use the supplier cannot confirm, or on a part that turns out to be military. Here is how the rules sort parts, why suppliers ask what they ask, and what to have ready before you order.
This is a plain-language overview of US regulations as published on 19 September 2026, not legal advice. Classification and licensing depend on the specific part and transaction; for a real case, rely on the exporter's determination and your own adviser.
Two rulebooks: EAR and ITAR
- EAR — the Export Administration Regulations (15 CFR parts 730–774), run by the Commerce Department's Bureau of Industry and Security (BIS). Commercial and dual-use items, including almost all civil aircraft parts.
- ITAR — the International Traffic in Arms Regulations (22 CFR parts 120–130), run by the State Department's Directorate of Defense Trade Controls (DDTC). Defense articles on the US Munitions List (USML), including military aircraft (Category VIII) and military gas turbine engines (Category XIX).
The EAR follow the part, not the seller: US-origin items are subject to them “wherever located”, so a US-made part stocked in Europe or Asia is still covered when sold on. And the US company that ships a part abroad is the exporter, which must determine whether a license is needed. MG-AVIATION, headquartered in Orlando, Florida, is subject to these rules like any US supplier.
In supplier quotes we received between June and September 2026, only about a third of the lines said where the part ships from. Where they did, roughly two in three named the United States; most of the rest named the Netherlands, Panama, the United Kingdom, France or China. Ships-from is a logistics fact, not an export-control one: a US-origin part quoted out of Amsterdam is still subject to the EAR on its next move.
EAR99, 9A991, 600 series: how a part is classified
Under the EAR, an item either has an Export Control Classification Number (ECCN) on the Commerce Control List (CCL), or it is EAR99: subject to the EAR but not listed. The ones aircraft parts buyers meet most:
| Classification | Typical aircraft items | What it usually means abroad |
|---|---|---|
| EAR99 | Standard hardware such as bolts, nuts, washers and springs | No license to most destinations. Still restricted for embargoed countries, listed parties and prohibited end uses. |
9A991, mostly 9A991.d | Parts specially designed for civil aircraft, not listed elsewhere; certain aero engines | Anti-terrorism (AT) controls only. No license to most destinations. |
7A994 | Avionics and airborne communication and navigation equipment, not listed elsewhere | AT only; in practice like 9A991. |
Higher-control ECCNs, e.g. 7A003, 9A001 | Certain inertial measurement systems and aero engines with listed performance features; generally not the civil-certified units on airliners, which these entries exclude | National security controls (missile controls for some); a license to most countries outside Australia, Canada and the UK. |
9A610 (“600 series”) | .x: parts specially designed for military aircraft. .y: listed low-sensitivity items such as tires and galleys | .x: a license everywhere except Australia, Canada and the UK, absent a license exception. .y: mainly China, Russia and Venezuela, plus embargoed destinations. |
| USML Category VIII or XIX (ITAR) | Defense articles for military aircraft and engines | A DDTC license for any export (see below). |
Two traps follow. A part specially designed for a civil aircraft falls into 9A991.d, the catch-all for aircraft parts “not elsewhere specified”, so “it's for an airliner, so it's EAR99” is a shortcut, not a classification. Standard hardware is the usual exception: fasteners, washers, spacers, springs and wire are released from “specially designed” regardless of form or fit, so they are normally EAR99. The opposite trap: a part specially designed for a military aircraft stays in 9A610 or on the USML however ordinary it looks, unless it is one of the released standard items above (the ITAR has the same release).
Who decides the classification
The exporter. BIS tells exporters to get the ECCN from the manufacturer, producer or developer, or to request a formal classification (15 CFR 748.3). DDTC settles whether an item is on the USML at all, through a commodity jurisdiction determination. Ask which classification a supplier applies, and keep it if you will resell the part. Asking to “just mark it EAR99” gets nowhere: the classification belongs to the part, not the paperwork.
Where it is going: the destinations that change the answer
For EAR99 and AT-only items such as 9A991 and 7A994, the Commerce Country Chart itself requires no license for any listed country; Cuba, Iran, North Korea and Syria are referred to the embargo rules. For ordinary aircraft parts, requirements come mainly from these:
| Destination | What applies to aircraft parts, broadly |
|---|---|
| Cuba, Iran, North Korea, Syria (Country Groups E:1 and E:2) | Practically everything needs a license; for Iran, BIS rules and a comprehensive OFAC embargo apply together. Syria was eased in September 2025: a license is still required, but applications supporting civil services, aviation among them, are reviewed with a presumption of approval. |
| Russia and Belarus | A license for every CCL item and for EAR99 aircraft parts under tariff heading 8807 (Supplement No. 4 to Part 746), reviewed under a policy of denial with narrow exceptions. |
| Crimea and the so-called DNR and LNR regions of Ukraine | A license for almost every item subject to the EAR (15 CFR 746.6). |
| China (including Hong Kong), Burma, Cambodia, Nicaragua, Venezuela | A license for 9A991 parts and 7A994 avionics when the exporter knows they are for a military end use or military end user. |
The aircraft counts too. Under 15 CFR 744.7, a part may not go to or for the use of a foreign aircraft unless it could be shipped without a license, or under a license exception, to three countries: where the aircraft is, where it is registered, and the country (or its nationals) that controls, leases or charters it. Hence the questions about registration and operator.
Hong Kong is China under the EAR
Since 23 December 2020, following Executive Order 13936, exports, reexports and transfers to Hong Kong are treated under the EAR as transactions destined for the People's Republic of China. For aircraft parts:
- The China military end-use and end-user rule applies in Hong Kong.
- Every CCL item, 9A991 included, shipped to China generally needs a US export filing whatever its value; the rule names Hong Kong explicitly.
- Hong Kong has its own licensing: most items controlled for national security, nuclear, missile or chemical and biological reasons need a Hong Kong license even when the US export needs none.
- A US-origin part moving on from Hong Kong is a reexport under the EAR.
End user and end use: why you are asked
Many EAR obligations turn on what the exporter knows about end use, end user and destination. Under BIS's “Know Your Customer” guidance, without red flags, an exporter may rely on the customer's representations; with them, it must inquire, and if they cannot be explained, refrain or apply for a license. General Prohibition Ten forbids going ahead with knowledge that a violation has occurred or is about to. Your written statement is what the supplier relies on.
- End-use and end-user statement. At BIS's March 2025 Update Conference, a BIS official recommended that exporters generally get one for all items subject to the EAR, EAR99 included. It typically states your line of business and intended use, with a certification against prohibited reexport signed by an authorized official.
- Form BIS-711. This Statement by Ultimate Consignee and Purchaser supports certain license applications: required for 600-series major defense equipment, accepted instead of the PRC End-User Statement for replacement parts worth up to $75,000 that service earlier exports, and requested by BIS case by case. A signed one cannot be corrected, only replaced.
- The ultimate consignee is not a forwarder. It is the principal party abroad that receives the items. Your forwarder is an intermediate consignee.
What to have ready before you order
| Have ready | Why a US supplier will typically need it |
|---|---|
| Legal names and street addresses of the purchaser, ultimate consignee and end user | Every party is screened and named in the export filing. |
| Your freight forwarder, named as such | A forwarder shown as the final destination is a BIS red flag. |
| Aircraft type, registration and operator, for aircraft-specific parts | The three-country test for foreign aircraft. |
| End use in one sentence (installation, MRO stock, resale) and any onward country | Military end-use rules; a US-origin part stays under the EAR when it moves on. |
| A signed end-use and end-user statement on your letterhead | The documentary basis for relying on what you said. |
| Any import license your own country requires | Hong Kong's, for example, for strategically controlled items. |
| For 600-series or ITAR parts: time | A license must be in hand before anything ships. |
Much of this belongs in the RFQ itself, and export paperwork is one more reason stock and time to your door can differ.
Sanctions: OFAC and the Iran aviation designations of 8 September 2026
Export controls run alongside sanctions administered by the Treasury's Office of Foreign Assets Control (OFAC). Parties on OFAC's Specially Designated Nationals list or BIS's Entity List are off limits or need a license, whatever the part; the free Consolidated Screening List searches the Commerce, State and Treasury lists at once.
For Iran, without OFAC authorization nothing may be supplied from the United States, or by a US person, to a buyer in a third country with knowledge or reason to know it is intended for Iran, and non-US persons may not, with knowledge or reason to know that it is intended for Iran, reexport US-origin goods that need a US license for Iran.
On 8 September 2026 OFAC sanctioned 36 targets for supporting Iran's aviation sector: 27 Iranian airlines, and nine companies and individuals in the UAE, Türkiye, Malaysia, Kazakhstan and the UK that served Mahan Air, itself sanctioned since 2011, as intermediaries, operators, cargo agents or general sales agents. Treasury says Iran uses “front companies and other pass-through entities in third countries to obfuscate the ultimate Iranian end-user of U.S.-origin aircraft and aviation-related materials”, and that Mahan Air received at least three B-777s diverted through the UAE and Oman in summer 2026. The same day FinCEN issued FIN-2026-Alert006, a list of red flags for Iranian aviation procurement.
Russia has its equivalent. BIS publishes a list of aircraft that flew into Russia in apparent violation of the EAR; refueling, maintenance, repair or spare parts for them fall under General Prohibition Ten.
Red flags, and how a legitimate buyer avoids them
A legitimate buyer can answer most of the BIS and FinCEN red flags before anyone asks.
| Red flag | Source | What to provide instead |
|---|---|---|
| Reluctance to say what the part is for, or whether it will be reexported | BIS | The end use, and any resale country, in the RFQ or PO |
| A freight forwarder as the final destination | BIS | The end user, with the forwarder shown as intermediate consignee |
| Vague delivery dates or an abnormal route | BIS | Your real routing |
| A new company with opaque ownership and little online presence in a transshipment hub, buying many aircraft parts | FinCEN | Registration, ownership and trade references |
| A general trading company in a free trade zone that does not normally deal in aviation | FinCEN | Evidence of your aviation business |
| Parts ordered in one country for delivery to a forwarder in another | FinCEN | The chain from purchaser to end user |
| Claims of OFAC or BIS authorization without copies | FinCEN | A copy of the authorization |
Each flag has to be resolved before the part ships, which is why a clear order moves and a vague one stops. And no explanation turns a third country into a route to an embargoed one.
Reexport: de minimis and foreign direct product, briefly
- A US-origin part resold as it is stays subject to the EAR, with the same tests applied to the new destination, end user and end use.
- A foreign-made item with US-origin controlled content is outside the EAR if that content stays within the de minimis level: 25% for most destinations, 10% for Country Groups E:1 and E:2. There is no de minimis level for 600-series content (paragraphs .a to .x) bound for arms-embargoed countries (Country Group D:5, China included).
- The foreign direct product rules can bring foreign-made items produced with certain US technology or software under the EAR, with specific versions for Russia, Belarus and Iran.
- Under the ITAR, any resale or reexport beyond the licensed end user, end use or destination needs DDTC's written approval first.
ITAR parts cannot simply be sold abroad
If a part is on the USML, every export needs DDTC approval before it ships unless an ITAR exemption applies, and the applicant must be registered with DDTC. For significant military equipment, DDTC also needs a nontransfer and use certificate (DSP-83) signed by the foreign consignee and end user, and may ask your government to sign it too. For Belarus, Burma, China, Cuba, Iran, North Korea, Syria and Venezuela the policy is denial, and 126.1 applies denial policies to further countries, Russia among them.
In practice an ITAR part cannot be quoted to a buyer abroad as “stock, ships tomorrow”. Expect any offer to be conditional on the license, on a timeline set by licensing rather than the shelf; 600-series parts are one step lighter, with the same logic. And check who you buy such parts from: see how to verify an aircraft parts supplier.
Put the export details in your RFQ
Buying from outside the US? Name the end user, the final destination and, for aircraft-specific parts, the registration and operator in the request. Then email the file as it is — Excel, PDF, a scan or the body of an email — to [email protected], and your inquiry will be reviewed by a specialist within one business day. Our prices are Ex Works our warehouse in Orlando, Florida, and where the supplier states it, each line shows the country the part ships from.
Our client portal, RFQ Radar, keeps every quote, order and invoice in one place.
Sources
- eCFR — 15 CFR Part 774, Supplement No. 1: Commerce Control List (ECCNs 7A003, 7A994, 9A001, 9A610, 9A991)
- eCFR — 15 CFR 772.1, Definitions (“specially designed”)
- eCFR — 15 CFR 734.3, 734.4 (de minimis) and 734.9 (foreign direct product rules)
- eCFR — 15 CFR Part 738, Supplement No. 1: Commerce Country Chart and Part 740, Supplement No. 1: Country Groups
- eCFR — 15 CFR 744.7 (foreign aircraft) and 744.21 (military end use and end user)
- eCFR — 15 CFR Part 746: 746.6, 746.8, 746.9, Supplement No. 4
- eCFR — 15 CFR Part 748: 748.3, 748.5, 748.11 (Statement by Ultimate Consignee and Purchaser)
- eCFR — 15 CFR 758.1 (export filing, note on Hong Kong) and 758.3 (responsibilities of parties)
- eCFR — 15 CFR Part 732, Supplement No. 3: BIS's “Know Your Customer” Guidance and Red Flags; 736.2 (General Prohibition Ten)
- eCFR — 22 CFR (ITAR): 120.4, 120.41 (“specially designed”), 123.1, 123.9, 123.10, 126.1
- eCFR — 31 CFR (Iranian Transactions and Sanctions Regulations): 560.204, 560.205
- BIS — Hong Kong export controls
- BIS — Classify your item
- BIS — Commerce identifies aircraft exported to Russia in apparent violation of the EAR (press release, 18 March 2022)
- U.S. Department of the Treasury — Treasury Grounds Iranian Airlines with Sweeping Sanctions Action (press release, 8 September 2026)
- FinCEN — FIN-2026-Alert006: FinCEN Alert to Counter Iranian Procurement Efforts for its Commercial Aviation Industry (8 September 2026)
- International Trade Administration — Consolidated Screening List
- Davis Wright Tremaine — Protect Yourself: U.S. Exporters Advised to Obtain End-Use and End-User Statements for All Exports, Including EAR99 Items (April 2025)