The State Department's final rule on International Traffic in Arms Regulations took effect September 15, 2025, with targeted revisions to the U.S. Munitions List (USML). Coverage from Federal Register, C&M Trade Law, and K&L Gates.
Key changes
- Category IV (spacecraft) revised to move some items from ITAR to EAR jurisdiction
- Category XV (launch systems) similarly revised
- Items no longer warranting USML inclusion removed
- Items warranting inclusion added; certain entries clarified
- Cambodia removed from ITAR 126.1 prohibited countries list — defense article requests now reviewed case-by-case
- New license exemption for unmanned underwater vehicle (UUV) activities
Why ITAR-to-EAR matters
Items under ITAR require Directorate of Defense Trade Controls (DDTC) authorization for any international engagement — even speaking to international partners. Under EAR, the bar is lower and more commercial. The shift means fewer firms need DDTC approval just for cross-border discussions on covered items.
BIS Affiliates Rule suspension
Separately, BIS imposed a one-year suspension of the September 30, 2025 "Affiliates Rule." After the suspension ends November 10, 2026, BIS will reapply the changes, using the time to review impact on national security and foreign policy.
What contractors need to do
- Re-classify products in your catalog against the revised USML — what was ITAR may now be EAR
- Update DDTC registration if your jurisdiction changed
- Watch for the Affiliates Rule re-application Nov 2026 — supply chain compliance changes
- For UUV firms: the new license exemption is a real opportunity