Department Of State Issues Final Rule, Effective Sept. 15, 2025, Updating ITAR And Targeted Revisions To The U.S. Munitions List

On August 27, 2025, the Department of State published a final rule amending the International Traffic in Arms Regulations ("ITAR") and updating the U.S. Munitions List ("USML"). The rule, effective September 15, 2025, implements changes following public comment and periodic review required under the Arms Export Control Act.

The latest ITAR amendments remove certain items from control, including lead-free birdshot ammunition and GNSS anti-jam/anti-spoofing systems, based on assessments that these no longer provide a critical military or intelligence advantage. At the same time, new controls have been added for advanced aircraft parts and large unmanned underwater vehicles ("UUVs") with specific military features, reflecting ongoing technology developments and national security priorities. The Department also clarified definitions for terms such as "foreign advanced military aircraft" and "mission systems," and added the F-47 fighter to the USML. These revisions respond directly to industry feedback and public comments, with refinements to controls for aircraft radar, IEDs, body armor, antennas, and other entries.

A significant feature of the rule is a new exemption in ITAR §126.9(u), which allows for the temporary export, reexport, and import of certain large UUVs (under 8,000 lbs.) for scientific research, civil infrastructure, or search and rescue purposes, provided there is no transfer of registration, control, or ownership to a foreign person. This exemption is intended to facilitate legitimate civilian and research uses of advanced underwater technology while maintaining strict controls against diversion to military applications.

For items removed from the USML, exporters must now review jurisdiction and licensing procedures under the Export Administration Regulations ("EAR"). Existing DDTC licenses for transitioning items will remain valid for up to three years to allow industry time to adjust to the new regulatory environment.

These targeted revisions are part of the Department's ongoing effort to keep ITAR focused on items that provide a critical military or intelligence advantage and to ensure the USML reflects technological and commercial realities. Exporters, manufacturers, and research institutions should review the revised USML and ITAR provisions to ensure compliance.

Crowell will continue to monitor developments in U.S. export controls and their impact on industry.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.