9D104 Category 9D

“Software” specially designed or modified for the “use” of equipment controlled by ECCN 9A001, 9A012 (for MT controlled items only), 9A101 (except for items in 9A101.b that are “subject to the ITAR”, see 22 CFR part 121), or 9A106.d.

This entry states the items are subject to the ITAR. The analysis runs through the U.S. Munitions List, not the EAR.

Category 9: Aerospace and Propulsion

Reasons for control

MT: Missile technology
AT: Anti-terrorism

Country chart

Control	Column
AT applies to entire entry	AT 1
MT applies to entire entry	MT 1

List-based license exceptions

Exception	As stated in the entry
TSR	N/A

Items

Items: The list of items controlled is contained in the ECCN heading.

Related controls

“Software” for commodities specified in ECCNs 9A005 to 9A011, 9A103 to 9A105, 9A101.b (except for items that are subject to the EAR), 9A106.a, .b, and .c, 9A107 to 9A109, 9A111, 9A115 to 9A118 is “subject to the ITAR” (see 22 CFR parts 120 through 130).

Notes

Note: For a manned aircraft converted to operate as an unmanned aerial vehicle specified in 9A012 and controlled for MT reasons, 9D104 includes “software”, as follows: a. “Software” “specially designed” or modified to integrate the conversion equipment with the aircraft system functions; b. “Software” “specially designed” or modified to operate the aircraft as an unmanned aerial vehicle.

Source: eCFR, version 2026-08-01, retrieved 2026-08-20T04:04:59+00:00.