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22 CFR §121.1 Category I

USML Category I: Firearms, Close Assault Weapons and Combat Shotguns

USML Category I covers firearms with a bore of .50 caliber (12.7 mm) or less that are designed or modified for military use, including rifles, carbines, pistols, revolvers, and shotguns specifically designed for combat. The category also captures accessories directly associated with these weapons — including silencers, suppressors, and military-specific mounts — as well as technical data and defense services related to their design, manufacture, or modification.

TC

Reviewed by

Trenton Crouch

Founder, ITAR Screen

Trenton is the founder of ITAR Screen and Gideon Dynamics. He built ITAR Screen to give defense contractors and dual-use exporters fast, auditable USML classification and denied-party screening without the complexity of enterprise compliance platforms.

Last reviewed:

Coverage

What Category I covers

USML Category I covers firearms with a bore of .50 caliber (12.7 mm) or less that are designed or modified for military use, including rifles, carbines, pistols, revolvers, and shotguns specifically designed for combat. The category also captures accessories directly associated with these weapons — including silencers, suppressors, and military-specific mounts — as well as technical data and defense services related to their design, manufacture, or modification.

Common controlled items

  • M16/M4 assault rifles and variants
  • Military service pistols (M9, M17/M18 series)
  • Combat shotguns with folding stocks or breaching configurations
  • Suppressors and silencers designed for military use
  • Flash suppressors and muzzle brakes for military weapons
  • Conversion kits that render a firearm to automatic fire
  • Grenade launchers attaching to or integrated with Category I weapons

EAR / ECCN

EAR overlap

Commercial sporting firearms and shotguns not meeting Category I military specifications are generally controlled under EAR at ECCN 0A501 (rifles/pistols) or 0A502 (shotguns). Manufacturers must carefully evaluate whether a firearm's design history or modifications trigger ITAR jurisdiction before assuming EAR applicability.

Licensing

Typical license requirements

Permanent exports require a DSP-5 license from the State Department's Directorate of Defense Trade Controls (DDTC). Temporary exports and imports use DSP-73 and DSP-85 respectively. Several exemptions exist under 22 CFR §123 for law enforcement exports and intra-NATO transfers, but each exemption has strict conditions.

Regulations

Key citations

  • 22 CFR §121.1 Category I
  • 22 CFR §123 — Licenses for the Export and Temporary Import of Defense Articles
  • 22 CFR §126.1 — Prohibited Exports and Sales to Certain Countries

Always verify against the current version of the USML (22 CFR Part 121) on the eCFR. ITAR Screen classifications are versioned against the USML reference at the time of the call.

Primary sources

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