How the Munitions List is organized

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1. Two categories with no fixed contents

Most categories of the United States Munitions List (USML) describe a type of equipment. Two do not. Category XVII covers "Classified Articles, Technical Data, and Defense Services Not Otherwise Enumerated" (22 CFR 121.1). Its single paragraph, marked with an asterisk, reaches all articles classified in the interests of national security and not listed elsewhere, together with the related technical data and defense services. Classified articles count as Significant Military Equipment in any event, because that term expressly includes all classified articles enumerated on the list (22 CFR 120.36). Most other categories also end with an asterisked entry of their own for classified items, so Category XVII catches what those entries do not.

Category XXI covers "Articles, Technical Data, and Defense Services Not Otherwise Enumerated" (22 CFR 121.1). Paragraph (a), with an asterisk, allows any article not listed on the USML to be placed in the category until the right category is amended to describe it. Paragraph (b) adds the directly related technical data and defense services. A note gives the key decisions to the Director of the Office of Defense Trade Controls Policy. They are whether to designate an article, whether to impose a catch-all control, whether it is Significant Military Equipment and whether it is excluded from particular license exemptions.

A Category XXI designation follows a case-by-case test (22 CFR 120.12). The question is whether the article or service has a critical military or intelligence advantage warranting control. The test takes into account its function and performance capability and the controls other nations impose, including the Wassenaar Arrangement and other multilateral controls. Articles in a Category XXI determination also appear in the parts entries for aircraft in Category VIII and engines in Category XIX (22 CFR 121.1).

2. How every category is built

The regulations describe a common structure (22 CFR 120.10). Categories are organized by alphanumeric paragraphs and subparagraphs. They usually start with end items, then major systems and equipment, then parts, components, accessories and attachments, and finally technical data and defense services directly related to the category. Items in paragraphs preceded by an asterisk are Significant Military Equipment, and entries ending in (MT) are on the Missile Technology Control Regime Annex.

The list is not fixed. The articles, services and technical data on it are designated under sections 38 and 47(7) of the Arms Export Control Act, and changes in designations are published in the Federal Register (22 CFR 120.10). The official electronic text of the list shows amendments published in July, August and September 2026 alone (22 CFR 121.1).

3. Features that repeat across categories

Several features recur in category after category (22 CFR 121.1). Most categories include an asterisked entry for anything classified, containing classified software or being developed using classified information, in some cases limited to software tied to defense articles or 600 series items. About half have a technical data paragraph that also reaches classified data about matching Commerce Control List entries. All except Categories XVII and XXI have a paragraph (x), which lets items under the Export Administration Regulations (EAR) appear on a license where the purchase documentation includes them.

Many categories also have a paragraph for developmental articles funded by the Department of Defense (22 CFR 121.1). Each such paragraph excludes articles in production, articles placed under the EAR by a commodity jurisdiction determination, and articles identified in the funding document as developed for both civil and military applications. Each applies only from a stated date, and the dates differ. They include April 16, 2014 for aircraft, July 8, 2014 for surface vessels, materials and submersibles, and January 5, 2015 for energetic materials and protective equipment. Later dates apply to military electronics, to fire control and imaging, and to guns and ammunition.

4. The Commerce entries that sit alongside

Many categories point to matching Export Control Classification Numbers (ECCNs) on the Commerce Control List (22 CFR 121.1). Examples include 0A606 for military ground vehicles not in Category VII, 8A609 for vessels, 9A610 for aircraft and 9A619 for engines. Others are 3A611 for military electronics parts, 7A611 for fire control and guidance items, and 9A515 for spacecraft. Those entries cover military items that the USML does not list.

Commerce has jurisdiction over its own list and the other items subject to it (22 CFR 120.5). Articles not controlled on the USML may be subject to another agency’s regulations (22 CFR 120.11). How jurisdiction is decided in doubtful cases is covered in commodity jurisdiction and the order of review.

5. The twenty-one categories

The list runs to twenty-one categories, each with its own heading (22 CFR 121.1). Weapons and munitions come first: Category I, firearms, Category II, guns and armament, Category III, ammunition and ordnance, and Category IV, rockets, missiles and munitions. Category V covers explosives, energetic materials and propellants.

Platforms follow (22 CFR 121.1). They are Category VI, surface vessels of war, Category VII, ground vehicles, and Category VIII, aircraft. Category IX covers training equipment and training, and Category X personal protective equipment.

Equipment and materials come next (22 CFR 121.1). Military electronics in Category XI are covered in two parts, sonar, radar and electronic warfare and communications, sensors and components. Category XII is also in two parts, fire control, lasers and night vision and guidance, navigation and components. Category XIII covers materials, cryptography and armor.

The later categories are more specialized (22 CFR 121.1). Category XIV covers toxicological agents and associated equipment, and Category XVI nuclear weapons related articles. Category XV covers spacecraft, Category XVIII directed energy weapons, Category XIX gas turbine engines, and Category XX submersible vessels, which are covered with surface vessels in Categories VI and XX, naval vessels. Categories XVII and XXI close the list as described above.

Key terms

Category XVII	Classified articles, data and services not listed anywhere else on the USML.
Category XXI	A holding category for unlisted articles until the right category is amended.
Enumerated entry	An entry naming an article directly, which takes priority over a specially designed catch-all.
Paragraph (x)	The recurring paragraph that lets EAR items appear on an ITAR license with defense articles.
DS-4076	The Commodity Jurisdiction Determination Form filed with the Directorate of Defense Trade Controls.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

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