Revisions to the International Traffic in Arms Regulations (ITAR) and the United States Munitions List (USML) have been released to streamline compliance and enhance national security while facilitating trade with United States allies. The Department of State Directorate of Defense Trade Controls (DDTC) has released these changes to clarify the ITAR and remove defense articles from the USML that no longer warrant inclusion.
The DDTC has also added items to the USML to reflect advancements in technology and changes in defense needs. These changes will be in effect as of September 15, 2025.
Items Moved from ITAR to EAR Jurisdiction
The Department of State has removed items from the USML that no longer warrant inclusion. These items will likely be picked by the Bureau of Industry and Security (BIS). Organizations conducting license applications for items transitioning from the USML to the Commerce Control List (CCL) should refer to General Order No. 5 in supplement no. 1 to part 736 of the EAR. Parties currently holding licenses, agreements or approvals from the DDTC for transitioning items will not be affected by this change for a period of three years.
Revisions to the ITAR USML Categories
The following are highlights of changes to the USML. The latest revision of the USML should be consulted for classifications and licensing concerns..
USML Category III – Ammunition and Ordnance
Under provisions for enhanced projectile tips, the USML now excludes steel or tungsten shotgun pellets with diameters less than or equal to 0.230 inches. This exclusion pertains to lead free bird shot and therefore does not have a specific military function.
USML Category IV – Launch Vehicles, Guided Missiles, Rockets, Torpedoes, Bombs, and Mines
The USML now includes new license exemptions for large Unmanned Underwater Vehicles (UUVs) for UUVs having military, scientific, and commercial applications. The USML will now authorize temporary exports, reexports, and temporary imports of UUVs having a weight of up to 8,000 pounds.
USML Category V – Explosives and Energetic Materials, Propellants, Incendiary Agents and their Constituents
Various pyrotechnic, binders, additives, and chemical precursors were added to this category of the USML. The Department notes CAS numbers indicated on the USML may not cover all substances and mixtures described in the associated USML entries.
USML Category VII – Ground Vehicles
Changes were made to define ITAR controlled vehicles as any vehicle meeting control parameters regardless of surface of operation, vehicle control type, or mode of locomotion.
USML Category VIII – Aircraft and Related Articles
The definition for AESA fire control radar on foreign advanced aircraft was revised to avoid the inadvertent inclusion of minor parts and components. The recently announced F-47, the Air Force’s Next Generation Platform was also added to the aircraft list is paragraph (h)(1). Additionally, descriptions for “specially designed” for foreign advanced military aircraft were expanded.
USML Category XI – Military Electronics
The description of counter-jamming equipment in USML Category XI(a)(4)(iii) now excludes GNSS anti-jam and GNSS anti-spoofing systems. The standard addresses Controlled Reception Pattern Antennas (CRPAs) that are applicable in military and critical applications where accurate positioning is essential.
USML Category XIX – Gas Turbine Engines and Associated Parts
AGT1500, CTS800, GE38, GE3000, HPW3000, MT7, T55, T408, or T700 engines are now licensed by the Department of Commerce when intended use is for aircraft controlled under ECCN 9A610 but are to be are to be controlled under the ITAR for all other circumstances. Various other engine types were added to the USML.
USML Category XX – Submersible Vessels and Related Articles
A new exemption will be available for the temporary export, reexport, and temporary import of UUVs described in USML Category XX(a)(10) under 8,000 pounds. This includes provisions for defense services for those UUVs, when used for civil purposes.
USML Category XXI – Articles, Technical Data, and Defense Services not Otherwise Enumerated
A note was added stating that the Director, Office of Defense Trade Control Policy reserves the right to designate catch-alls, exclusions, or designations of Significant Military Equipment (SME) for articles under this category.
CVG Strategy Export Compliance Management Programs
Revisions to the ITAR reflect a proactive approach to adapting to technological advancements and international security dynamics. ITAR developments are continuing to add complexity for businesses engaged in sales of items that are intended for international sales international sales. Failure to comply with regulations can result in criminal prosecution including imprisonment and fines. It can also result in civil penalties and disbarment from export activities.
Export Compliance Management Programs establish clearly defined policies and procedures for all departments within an organization. They ensure that registration, item classifications, license applications, denied part screening, and security measures are taken that will prevent violation. They also ensure that training, auditing, and record keeping are maintained according to requirements.
CVG Strategy can help you understand revisions to ITAR and EAR, and help you establish a coherent and effective export compliance program. We can perform export control classifications, perform audits, assist in filings for export licenses and educate your team. Regardless of whether your business falls under EAR or ITAR, CVG Strategy has the expertise to help.