U.S. State Department revises munitions list with targeted changes
Date of publication: August 29, 2025
The U.S. Department of State published a final rule on August 27, 2025, amending the International Traffic in Arms Regulations (ITAR) and the U.S. Munitions List (USML), effective September 15, 2025. This final rule supersedes the January 17, 2025 interim rule, consolidating all changes into a single comprehensive update.
Key updates by category
Enhanced aircraft controls (category VIII)
Added
: F-47 aircraft (Next Generation Air Dominance Platform) has been added to ensure specially designed components remain controlled after the aircraft enters production.Exoskeleton technology controls (category X)
Added:
New controls describe developmental exoskeletons funded by DoD, with standard exclusions for items in production or documented as subject to EAR.Improved navigation system access (category XI)
Removed
: The Department modified controls to exclude Controlled Reception Pattern Antennas (CRPAs) for Position, Navigation, and Timing applications and GNSS anti-jam/anti-spoofing systems to facilitate civil global navigation system resiliency. These items are now subject to EAR jurisdiction, potentially opening new export opportunities for civil navigation applications.Chemical agent controls (category XIV)
Added
: Additional nerve agents and defoliant constituents have been added to strengthen controls on chemical warfare agents.Aircraft engine controls (category XIX)
Added
: Specific DoD-funded aircraft engines (XT900) have been added to maintain control over advanced propulsion technologies.Underwater vehicle controls and new exemptions (category XX)
Added
: New controls apply to large unmanned underwater vehicles with anti-recovery features or those exceeding 3,000 pounds with extended operational capabilities. However, a new license exemption (§ 126.9(u)) allows certain activities with vessels up to 8,000 pounds for scientific research, natural resource exploration, commercial infrastructure maintenance, or search and rescue operations.Additional items removed from USML:
- Lead-free birdshot ammunition from Category III
- Redundant technical data controls from Category IX
Definition clarifications
The final rule includes important clarifications to technical definitions, including AESA radar in fire control systems and "integrated" electronic warfare systems, providing greater clarity for defense technology companies on classification requirements.
Impact on global trade operations
For defense & aerospace companies
- Review supply chains for items transitioning between ITAR and EAR jurisdiction
- Update compliance procedures for newly controlled items, particularly F-47 components and XT900 engines
- Consider the new underwater vehicle exemption for applicable research and commercial activities
- Review technical definitions for AESA radar and integrated EW systems for proper classification
For technology companies
- Assess opportunities from removal of certain GNSS systems from USML controls, now under EAR jurisdiction
- Evaluate civil navigation technology export potential with reduced licensing requirements
- Review exoskeleton development programs for potential ITAR implications
For maritime & research organizations
- Understand new controls on large underwater vehicles
- Evaluate eligibility for the new license exemption for scientific and commercial activities
- Ensure compliance with weight and operational thresholds
Compliance requirements
- Effective date: September 15, 2025
- Companies have until the effective date to prepare for implementation
- Existing licenses remain valid under grandfathering provisions outlined in the rule
- This final rule consolidates and supersedes the January 17, 2025 interim rule
Conclusion
These regulatory changes reflect evolving priorities in national security while supporting legitimate commercial and research activities. The State Department's revisions balance security concerns with enabling civil applications, particularly in navigation technology and underwater research operations. The transition of certain items from ITAR to EAR jurisdiction creates new opportunities for commercial exports.
Companies should immediately review their product portfolios and supply chains to ensure continued compliance with these updated regulations.
These changes will be available in ONESOURCE Global Trade Content as part of ECN/ML List.
For more information on how ONESOURCE Global Trade solutions can assist you in managing these regulatory changes, please contact your Account Manager or Customer Success Manager.