May 4, 2006
Question: Bullet-proof windshield glass is used in ground vehicles having armored or ballistic
protection. Certain armored ground vehicles are classified under Export Control Classification
Number (ECCN) 9A018.b. on the Commerce Control List of the Export Administration
Regulations (EAR); others are classified as EAR99. If bullet-proof windshield glass is exported
separately from a vehicle, is it correctly classified under ECCN 9A018.b. or as EAR99?
Answer: Parts and components are classified under ECCN 9A018.b. only if they are for “ground
transport vehicles ...designed or modified for non-combat military use.” Parts and components
are not classified under ECCN 9A018.b. if they are for other types of vehicles classified under
ECCN 9A018.b. or for vehicles that are classified as EAR99. Therefore, bullet-proof windshield
glass is classified as EAR99 if it is for:
1) “unarmed all-wheel drive vehicles capable of off-road use which have been manufactured or
fitted with materials to provide ballistic protection to level III” classified under ECCN 9A018.b.;
2) “ground vehicles having armored or ballistic protection” that are classified as EAR99
pursuant to section 770.2(h), interpretation 8, which provides that ECCN 9A018(b) does not
control civil automobiles (defined as passenger cars, limousines, vans or sport utility vehicles
designed for the transportation of passengers and marketed through civilian channels in the
United States) or trucks designed or modified for transporting money or valuables.
Bullet-proof windshield glass is classified under ECCN 9A018.b if it is for a ground transport
vehicle designed or modified for non-combat military use as described in section 770.2(h)(1) -
(2) of the EAR.