The U.S. Munitions List (USML), 22 CFR 121.1, has 21 categories, numbered I to XXI. Together they define the defense articles controlled by the International Traffic in Arms Regulations (ITAR), from firearms in Category I to articles not otherwise enumerated in Category XXI. Reading these categories is the first step of every jurisdiction decision, as explained in ITAR vs. EAR: which regulation controls your item?
The 21 USML categories
| Category | Title | Notes |
|---|---|---|
| I | Firearms and related articles | Since 2020, many commercial firearms have moved to the EAR (0x5zz entries); fully automatic and certain other firearms remain. |
| II | Guns and armament | Larger-calibre guns, howitzers, mortars. |
| III | Ammunition and ordnance | |
| IV | Launch vehicles, guided missiles, ballistic missiles, rockets, torpedoes, bombs and mines | |
| V | Explosives and energetic materials, propellants, incendiary agents | |
| VI | Surface vessels of war and special naval equipment | |
| VII | Ground vehicles | Tanks and armoured combat vehicles. |
| VIII | Aircraft and related articles | Specified military aircraft and parts. |
| IX | Military training equipment and training | |
| X | Personal protective equipment | For example, certain body armour and helmets. |
| XI | Military electronics | Radar, electronic warfare, specified communications. |
| XII | Fire control, laser, imaging and guidance equipment | Weapon sights, night vision above thresholds. |
| XIII | Materials and miscellaneous articles | For example, certain armour materials and cryptographic devices for military use. |
| XIV | Toxicological agents | Including chemical and biological agents, and equipment. |
| XV | Spacecraft and related articles | The most sensitive items; others moved to 9x515. |
| XVI | Nuclear weapons related articles | |
| XVII | Classified articles, technical data and defense services not otherwise enumerated | |
| XVIII | Directed energy weapons | |
| XIX | Gas turbine engines and associated equipment | For specified military aircraft. |
| XX | Submersible vessels and related articles | |
| XXI | Articles, technical data and defense services not otherwise enumerated |
The current text is in 22 CFR 121.1 on the eCFR, updated as rules take effect. DDTC also publishes guidance and notices.
How a USML category is structured
Each category is a positive list. Its paragraphs enumerate end items first, then parts, components, accessories and attachments, then technical data and defense services. Paragraphs marked with an asterisk are Significant Military Equipment (SME), which carries additional requirements, such as end-use certificates for some exports.
Parts and components are defense articles only when they are enumerated, or when they are "specially designed" under § 120.41 and not released. Many parts of ITAR end items are therefore on the Commerce Control List, either in the matching 600 series entry or elsewhere. See the specially designed test and ITAR or EAR? Worked examples. Technical data follows the same structure and has its own guide, technical data under the ITAR.
What is paragraph (x) in a USML category?
Many USML categories include a paragraph (x) for commodities, software and technology subject to the EAR that are used in or with defense articles. It lets DDTC authorise those EAR items on the same licence as the defense articles they go with. Licensing an EAR item under paragraph (x) does not make it a defense article; it remains subject to the EAR.
USML categories and the 600 series
Export control reform moved many items from these categories to the Commerce Control List (the history is in export control reform and the 600 series). The new entries mirror the USML:
- 9x610 for aircraft (VIII)
- 9x619 for engines (XIX)
- 0x606 for ground vehicles (VII)
- 3x611 for military electronics (XI)
- 9x515 for spacecraft (XV)
The list goes on for other categories. If an item is not on the USML, check its 600 series counterpart next. See 600 series ECCNs.
Can an item move off the USML?
Yes. It can move through revisions of the list, as happened in export control reform, or through a commodity jurisdiction determination that places it under the EAR.
Is the USML the same as the Wassenaar Munitions List?
No. Both cover military items, but the USML is a U.S. list with its own structure and scope. Foreign export regimes use their own lists based on international arrangements.
How to use the USML categories in a review
- Identify every category that could describe the item by its function. The customer does not decide it.
- Read the enumerated paragraphs.
- Apply "specially designed" to parts and components.
- If nothing describes the item, move to the EAR, 600 series and 9x515 first.
- If it is still unclear, request a commodity jurisdiction determination.
For commercial products, the categories reviewed most often are XI (radios, radar components and electronic warfare-adjacent products), XII (thermal imaging, night vision, lasers and sights), XIII (materials, armour and specialised cryptographic devices), XV (space and satellite components), and VIII and XIX (aircraft parts and engine components). Products used by the military can still sit outside all of them; defense articles vs. dual-use items covers that distinction.
USML review in ECCN.help
ECCN.help's scope check asks whether the item is described on the USML before any EAR entry is offered, and its references include the USML categories. Classification of EAR items then follows in the rule-based ECCN.help Classification Workflow.
ECCN.help provides research and assistance, not legal advice. Verify every result against the regulation.