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ITAR USML Categories Reference Table

The United States Munitions List in 22 CFR Part 121 is divided into 21 categories, numbered I through XXI. When someone says an item is ITAR controlled, the first question is which category. This reference lists all 21 for quick lookup and ERP flagging.

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Category	USML category title	Typical coverage (general guidance)	ERP flag suggestion
I	Firearms and Related Articles	Firearms, close assault weapons, combat shotguns and related items	Restrict item and drawings, screen all customers
II	Guns and Armament	Guns, howitzers, mortars, launchers and related articles	Flag item and technical data
III	Ammunition and Ordnance	Ammunition, fuze setting devices and related articles	Flag item, storage and shipping holds
IV	Launch Vehicles, Guided Missiles, Ballistic Missiles, Rockets, Torpedoes, Bombs, and Mines	Missiles, rockets and associated components	Flag item and program-level access
V	Explosives and Energetic Materials, Propellants, Incendiary Agents, and Their Constituents	Energetic materials and propellants	Flag item, add hazmat and export holds
VI	Surface Vessels of War and Special Naval Equipment	Warships and special naval equipment	Flag item and drawings
VII	Ground Vehicles	Military ground vehicles and specially designed components	Flag item and BOM children
VIII	Aircraft and Related Articles	Military aircraft and specially designed parts	Flag item, BOM and routing documents
IX	Military Training Equipment and Training	Training equipment, simulators and related technical data	Flag item and software builds
X	Personal Protective Equipment, Shelters, and Related Articles	Body armour, helmets and related protective items	Flag item and test data
XI	Military Electronics	Electronic equipment such as radar, countermeasures and C4ISR components	Flag item, firmware and design files
XII	Fire Control, Laser, Imaging, and Guidance Equipment	Fire control, targeting, night vision and guidance equipment	Flag item and calibration data
XIII	Materials and Miscellaneous Articles	Certain materials, cryptographic and other listed articles	Flag item and material specification
XIV	Toxicological Agents, Including Chemical Agents, Biological Agents, and Associated Equipment	Agents and associated equipment	Flag item with additional controls
XV	Spacecraft and Related Articles	Spacecraft, ground control and specially designed parts	Flag item, drawings and software
XVI	Nuclear Weapons Related Articles	Articles related to nuclear weapons design and testing	Restrict strictly, involve compliance
XVII	Classified Articles, Technical Data, and Defense Services Not Otherwise Enumerated	Classified items outside other categories	Handle under classified program rules
XVIII	Directed Energy Weapons	Lasers, high-power microwave and related systems	Flag item and technical data
XIX	Gas Turbine Engines and Associated Equipment	Military gas turbine engines and specially designed parts	Flag item, routing and tooling data
XX	Submersible Vessels and Related Articles	Submersibles and associated equipment	Flag item and drawings
XXI	Articles, Technical Data, and Defense Services Not Otherwise Enumerated	Catch-all category used after a determination	Flag only on written determination

This table lists category titles for orientation only. Actual control depends on the detailed paragraphs of 22 CFR Part 121 and the specially designed definition. Use a commodity jurisdiction request when jurisdiction is unclear, and consult qualified counsel.

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How to use the table

Search by number or by keyword in the title, such as electronics, aircraft or space. Use the note as orientation to decide which category paragraph to read in the regulation, then record the full citation on the item. The ERP flag column suggests a practical control for each category, for example restricting drawings and screening customers. It is a prompt for discussion with your compliance team, not a ruling.

How the USML is organised

Each category has an enumerated list of controlled articles, followed by technical data and defence services that relate to them. Many entries use the phrase specially designed, which has its own definition and release paragraphs. Categories VIII, XI, XII and XV are common for aerospace and electronics suppliers, but a single product can be a component of an assembly in a different category.

From category to ERP control

Put the USML category, or ECCN if the item falls under the EAR, in a controlled attribute on the item master. Use it to drive restricted document access, shipment holds, customer screening and licence checks. Tie child components in a bill of materials to the parent's classification and review them when design changes happen. Keep the decision record in a classification worksheet.

Record category and paragraph on the item
Block shipment until licence checks pass
Restrict drawings and models by role
Review when a design or supplier changes

Common mistakes

Frequent errors include assuming a commercial part is outside the USML because it is sold publicly, ignoring technical data and software, and classifying only the end item while its specially designed parts are also controlled. Another is copying a category from a customer purchase order without checking. When uncertain, request a commodity jurisdiction determination rather than guessing.

Frequently Asked Questions

How many USML categories are there?

There are 21 categories, numbered I through XXI, in 22 CFR Part 121. Categories XVII and XXI hold classified items and articles not otherwise enumerated, so they are used differently from the equipment categories.

Which USML category covers military electronics?

Category XI, Military Electronics, covers items such as radar, electronic combat equipment and certain communications and C4ISR components. Imaging and fire control equipment fall under Category XII, so check both when working with sensors.

How do I know if my part is ITAR controlled?

Read the detailed USML paragraphs, apply the specially designed definition, and document your reasoning. If jurisdiction is unclear, submit a commodity jurisdiction request to the State Department. A supplier label alone is not a determination.

Is ITAR the same as the EAR?

No. The ITAR, administered by the State Department, controls items on the USML. The EAR, administered by Commerce, controls other items on the Commerce Control List. An item is generally under one regime or the other, so jurisdiction comes first.

Netray can help carry category and jurisdiction data into your ERP and PLM controls using private, on-prem tooling.

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