On August 27, 2025, the Department of State, Directorate of Defense Trade Controls (DDTC) issued a final rule (90 FR 41778) which revises multiple entries across the United States Munitions List (USML). This follows and replaces the interim final rule published in January and will be effective September 15, 2025.
Similar, but not identical to the interim final rule, the rule revises a list of definitions in §121.0 and revises USML categories as follows:
Category III – Ammunition and Ordnance
Revises paragraph (d)(6) of USML Category III to exclude common lead-free birdshot ammunition.
Category IV – Launch Vehicles, Guided Missiles, Ballistic Missiles, Rockets, Torpedoes, Bombs, and Mines
Revises paragraph (c) to clearly control equipment specially designed for improvised explosive devices (IEDs).
Category V – Explosives and Energetic Materials, Propellants, Incendiary Agents, and Their Constituents
Makes minor revisions and corrections.
Category VII – Ground Vehicles
Revises Note 3 to USML Category VII to clarify the types of vehicles controlled to include systems described as robots:
Ground vehicles include any vehicle meeting the control parameters, regardless of: the surface upon which the vehicle is designed to operate (e.g., highway, off-road, amphibious, or rail); the manner of control of the vehicle (e.g., manual, remote, or autonomous); or the mode of locomotion of the vehicle (e.g., wheeled, tracked, or multi-pedal).
Category VIII – Aircraft and Related Articles
Clarifies catch-all controls for specially designed parts for specific U.S. and non-U.S. origin aircraft. VIII(h)(1) parts will not be released from VIII(h)(1) through subsequent use in USML Category XXI or “foreign advanced military aircraft.”
It also revises the list of U.S.-origin aircraft identified in VIII(h)(1), updating designations and adding the F-47, MQ-25, and RQ-170.
Category IX – Military Training Equipment and Training
Removes and reserves paragraph (e)(2) as redundant. IX(e)(2) technical data is already covered by IX(e)(1).
Category X – Personal Protective Equipment
Adds developmental exoskeletons to previously-reserved X(b) and revises the descriptions of body armor protective levels.
Category XI – Military Electronics
Revises paragraph (c)(10) to remove certain anti-jam antennas and exclude Controlled Reception Pattern Antennas (CRPAs) for Position, Navigation, and Timing (PNT). Both revisions are intended to support civil global navigation system resiliency.
Category XII – Fire Control, Laser, Imaging, and Guidance Equipment
Updates paragraph (d)(2)(ii) GPS receiving equipment to change references from “Precise Positioning Service” to “Protected Positioning Service.”
Category XIII – Materials and Miscellaneous Articles
Updates office names, revises armor protective levels and descriptions, and adds specific fluids to new paragraph (j)(3).
Category XIV – Toxicological Agents, Including Chemical Agents, Biological Agents, and Associated Equipment
Adds nerve agents and a defoliant and clarifies CARC controls.
Category XIX – Gas Turbine Engines and Associated Equipment
Revises paragraphs (d) and (f)(1) to include additional Department of Defense-funded aircraft engines in development. Revises paragraph (f)(2) to include related cooled structures for combustion chambers and liners.
Category XX – Submersible Vessels and Related Articles
Adds two new classes of uncrewed, untethered vessels equipped with anti-recovery features and larger systems with significant range or endurance to new paragraphs (a)(9) and (10).
Category XXI – Articles, Technical Data, and Defense Services Not Otherwise Enumerated
Moves text from paragraph (a) into a new note and adds considerations for designating an article USML Category XXI.
In response to concerns that the vessels added to XX(a)(10) are often suitable for natural resource exploration, infrastructure inspection, and oceanographic research, DDTC also added a new license exemption supporting their use to a new § 126.9(u):
This new exemption will authorize the temporary export, reexport, and temporary import of UUVs described in USML Category XX(a)(10) that meet the exemption’s size restriction of 8,000 pounds, as well as the provision of defense services in the maintenance, repair, operation, or use of those exempted UUVs, when the controlled activities involve one of the exemption’s described civil uses. It will also authorize a similar scope of brokering activities. However, this exemption will not be available if the activities entail the transfer of the vessel’s registration, control, or ownership to a foreign person.
Commerce Relaxes Export Controls on Syria
On September 2, 2025, the Department of Commerce, Bureau of Industry and Security, published a rule (90 FR 42315) relaxing export controls on Syria following the end of the Assad regime. Among other changes, the new rule revised the Export Administration Regulations (EAR) § 742.9 and § 746.9 to relax license review policies and restrictions. The rule also created a new License Exception Syria Peace and Prosperity (SPP) at § 740.5. SPP authorizes the export or reexport of EAR99 items to Syria unless another end-use or end-user control applies.
In addition to license requirements for items listed on the Commerce Control List (CCL), Syria remains is an ITAR §126.1(d)(1) proscribed country subject to a policy of denial and a member of EAR Country Groups D:5 and E:1.
BIS also published a press release on this action.
