USML Category XI: communications, sensors and components

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1. Military electronics, part two

Category XI of the United States Munitions List (USML) in the International Traffic in Arms Regulations (ITAR), "Military Electronics", runs from underwater systems and radar through to circuit boards (22 CFR 121.1). This piece covers paragraphs (a)(5) to (a)(12), the intelligence entry in paragraph (b), and the parts and components in paragraph (c). The first four entries are covered in Category XI, sonar, radar and electronic warfare.

2. Command, control and communications

Paragraph (a)(5), marked with an asterisk, covers command, control and communications systems, their computer and intelligence, surveillance and reconnaissance variants, and identification systems (22 CFR 121.1). They are caught if they meet any of five tests. The first is being specially designed to integrate, network or employ defense articles in USML entries that do not use the term specially designed. The second is incorporating American government identification friend or foe (IFF) Modes 4 or 5.

The third test is implementing counter-countermeasures against communication disruption, with radios incorporating HAVE QUICK I/II, SINCGARS or SATURN as examples (22 CFR 121.1). The fourth is being designed, rated or certified to NSTISSAM TEMPEST 1-92 or CNSSAM TEMPEST 01-02, to suppress compromising emanations of information bearing signals. The fifth is transmitting voice or data signals specially designed to elude electromagnetic detection. Those systems are Significant Military Equipment, marked by the asterisk (22 CFR 120.10).

3. Sensors and other equipment

Paragraph (a)(6) is reserved (22 CFR 121.1). Paragraph (a)(7) covers developmental electronic equipment funded by the Department of Defense. Standard exclusions remove equipment in production, equipment released to the Export Administration Regulations (EAR) by a commodity jurisdiction ruling, and dual civil and military developments. It applies to contracts and funding authorizations dated July 1, 2015, or later.

Paragraph (a)(8) covers unattended ground sensor systems that have all four listed features (22 CFR 121.1). They are automatic target detection, automatic tracking, classification, recognition or identification, self-forming or self-healing networks, and self-localization for geo-locating targets. Paragraph (a)(9) covers electronic sensors for non-acoustic anti-submarine or mine warfare, such as magnetic anomaly detectors. Paragraph (a)(10) covers sensors detecting concealed weapons at a standoff range greater than 45 m for personnel, or detecting vehicle-carried weapons, with certain concealed object detection equipment excluded.

Paragraph (a)(11) covers test sets specially designed for the radar, electronic warfare, communications and intelligence articles in the category (22 CFR 121.1). Paragraph (a)(12) covers direction finding equipment specially designed for certain Category IV missiles or Category VIII unmanned aircraft. Where that vehicle can carry 500 kg or more over 300 km or more, the (MT) annotation attaches. A note says this and the matching radar entry include terrain contour mapping, scene mapping and correlation, Doppler navigation radar, passive interferometer and imaging sensor equipment.

4. Intelligence systems

Paragraph (b), with an asterisk, covers electronic systems, equipment or software specially designed for intelligence purposes (22 CFR 121.1). They must collect, survey, monitor or exploit, or analyze and produce information from, the electromagnetic spectrum, whatever the transmission medium. Systems for counteracting those activities are covered too. The entry applies only where the item is not listed elsewhere in the ITAR.

5. Parts and components

Paragraph (c) lists nineteen groups of parts and components (22 CFR 121.1). The first is application specific integrated circuits and programmable logic devices configured for defense articles. An application specific integrated circuit is one developed and produced for a specific application or function, however many customers it has, and logic devices that have not been configured are not controlled. The next two are printed circuit boards and populated card assemblies with a layout specially designed for defense articles, and multichip modules with a specially designed pattern or layout. Versions made for 600 series items sit instead in Export Control Classification Number 3A611 on the Commerce Control List.

Transmit and receive modules and their microwave integrated circuits are covered where they meet four tests together (22 CFR 121.1). The tests cover saturated power output against frequency, fractional bandwidth of 5% or greater, a size limit tied to frequency, and at least one electronically variable phase shifter per channel. A note to the whole category releases modules made exclusively with homojunction CMOS silicon circuits on silicon substrates, and radars using only such modules.

Other entries set thresholds for high-energy storage capacitors, radio frequency circulators, polarimeters, digital radio frequency memory and vacuum electronic devices (22 CFR 121.1). The capacitor entry, for example, needs a rated voltage greater than 500 V, at least six discharges per minute, a full energy life of at least 10,000 discharges, and a stated energy density. Antennas with advanced beam and null steering or precise angle of arrival measurement are covered, excluding collision avoidance antennas meeting FAA standards. Radomes with frequency selective surfaces, ballistic protection or high temperature performance are included. So are underwater sensors and projectors for the category’s sonar systems, and their piezoelectric parts.

The list closes with tuners for electronic warfare and intelligence systems and high-temperature electronics for long-range unmanned aircraft and missiles (22 CFR 121.1). Hybrid computers for modeling such systems follow, then chaff and flare rounds for the category’s countermeasures equipment. Parts that modify the published properties of a controlled information security system or radio, such as its frequency range, algorithms or waveforms, are included. An asterisked entry catches anything classified, containing classified software tied to defense articles or 600 series items, or developed using classified information. For the classified software limb, a note limits it to parts and components that store, process or transmit classified software.

Several of the component entries turn on specially designed, and the general test applies (22 CFR 120.41). A part for use in or with a defense article is generally caught, but general purpose parts shown by contemporaneous development documents are not.

6. Technical data

The data and services tied to paragraphs (a) to (c) sit in paragraph (d) (22 CFR 121.1). It also controls classified technical data about items in ECCNs 3A611, 3B611, 3C611 and 3D611. Paragraph (x) covers accompanying EAR items.

Key terms

IFF Modes 4 and 5	American government identification friend or foe modes that bring equipment into paragraph (a)(5).
TEMPEST	Standards for suppressing compromising emanations of information bearing signals.
Unattended ground sensor	A sensor system with automatic detection and tracking, self-healing networks and self-localization.
ECCN 3A611	The Commerce entry for military electronics parts made for 600 series items.
Transmit/receive module	An assembly giving two-way amplitude and phase control of signals, controlled at stated thresholds.

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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